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Traffic Level and Electric Vehicle Assumptions used in Decarbonising Transport: A Better, Greener Britain

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Dear Department for Transport,

In the document Decarbonising Transport: A Better, Greener Britain, with respect to Figure 2: Decarbonising Transport domestic transport GHG emission projections, versus the baseline (page 45), I request you publish the following:

1) The assumed levels of road traffic (miles or kilometres) (split by cars, light goods vehicles and heavy goods vehicles) for the upper and lower boundaries of both the Baseline and Decarbonising Transport Projection for each year or five year period where you have made an assessment
2) The proportion of the miles or kilometres that are driven by electric vehicles for cars and, if available for light goods vehicles and heavy goods vehicles, for the upper and lower boundaries of both the Baseline and Decarbonising Transport Projection for each year or five year period where you have made an assessment. If you have assumed different technologies from battery electric may perform the decarbonisation role for goods vehicles then please publish your assumptions.

3) The full set of assumptions used in separating out the high and low projection lines as a result of "Short-term COVID-19 Uncertainty" as labelled on Figure 2.

Yours faithfully,

Greg Marsden

Department for Transport

Dear Sir/Madam,

I am writing to acknowledge receipt of your request for information which
has been allocated reference number P0020915.

A response will be issued to you in due course.

Regards,

Department for Transport
FOI Advice Team

show quoted sections

Nathan Warren, Department for Transport

1 Attachment

Dear Professor Greg Marsden,
Please see attached for the response from DfT. If you have any further
questions please do get in touch.
Regards,
Nathan

[1][IMG] Mr Nathan Warren 
Climate Change Strategy, Environmental Analysis

1/31 - 34 GMH, Great Minster House 33 Horseferry Road, London,
SW1P 4DR

07977 435558       
[2]Follow us on twitter @transportgovuk 

show quoted sections

Nathan Warren, Department for Transport

 

Hi Greg,

 

You will have seen the official response I sent on  Monday, I also wanted
to follow up directly with some further information, which I thought would
be helpful following our conversation last week. Even though as we
explained we cannot provide you with the full amount of detail you
requested. There is quite a lot of helpful information already in the
public domain. I picked out a couple of sections of published reports that
could be helpful below. I also respond below on future work with TASM and
a point of clarification.

 

Projections of sales for cars and vans

DfT published the Transitioning to Zero Emission Cars and Vans Delivery
Plan - page 5 includes ranges of ULEV delivery related to cars and vans

([1]https://assets.publishing.service.gov.uk...)

 

Projections of fleet uptake ZEVs by year and mode

BEIS published the Net Zero Strategy which included metrics of ZEV
deployment at the fleet level for key years - see page 326

([2]https://assets.publishing.service.gov.uk...)

 

Input into Road Traffic Projections

We discussed your engagement with TASM when developing their Road Traffic
Projections and we have subsequently spoken to the team. I can confirm
that they are keen to engage with you on this and Liz Jacobs has said
someone in her team will be in touch.

 

Uncertainty in projections

Finally, I reflected on one point made in the meeting, which I think we
did not adequately answer. I think you suggested that the uncertainty
range in the TDP modelling was all or largely down to COVID. However, the
range was down to a wide range of factors. As noted in the TDP text
"uncertainty bands around projections reflect uncertainty on the form of
final policy and uncertainties on future demand for road transport –
related to future trends in travel, uptake of connected and autonomous
vehicles, fuel prices, GDP growth, and historical volatility." So, the
COVID uncertainty is only one factor. In the short term uncertainty is
significant impacted by COVID assumptions, but in the longer term it is
the other factors that drive the range.

 

As noted we are keen to be as helpful as we can in future, and are happy
to point you to further information once it enters the public domain.

 

Regards,

Nathan

[3][IMG] Mr Nathan Warren 
Climate Change Strategy, Environmental Analysis

1/31 - 34 GMH, Great Minster House 33 Horseferry Road, London,
SW1P 4DR

07977 435558       
[4]Follow us on twitter @transportgovuk 

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References

Visible links
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2. https://assets.publishing.service.gov.uk...
3. https://www.gov.uk/government/organisati...
4. https://twitter.com/transportgovuk

Dear Department for Transport,

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

I am writing to request an internal review of Department for Transport's handling of my FOI request 'Traffic Level and Electric Vehicle Assumptions used in Decarbonising Transport: A Better, Greener Britain'.

Re: FOI Request TDP E0020915
I am writing to request an internal review of the FOI which I submitted on 7th March 2022.

"Dear Department for Transport,
In the document Decarbonising Transport: A Better, Greener Britain, with respect to Figure 2: Decarbonising Transport domestic transport GHG emission projections, versus the baseline (page 45), I request you publish the following:
1) The assumed levels of road traffic (miles or kilometres) (split by cars, light goods vehicles and heavy goods vehicles) for the upper and lower boundaries of both the Baseline and Decarbonising Transport Projection for each year or five year period where you have made an assessment
2) The proportion of the miles or kilometres that are driven by electric vehicles for cars and, if available for light goods vehicles and heavy goods vehicles, for the upper and lower boundaries of both the Baseline and Decarbonising Transport Projection for each year or five year period where you have made an assessment. If you have assumed different technologies from battery electric may perform the decarbonisation role for goods vehicles then please publish your assumptions.
3) The full set of assumptions used in separating out the high and low projection lines as a result of "Short-term COVID-19 Uncertainty" as labelled on Figure 2."

You subsequently responded on 1st April – REF E0020915

"Your request has now been considered under the Environmental Information Regulations 2004.
We have considered your request in accordance with the Environmental Information Regulations 2004 (‘the EIRs’) as the information you request falls within the definition of ‘environmental information’ in the EIRs.
Regulation 12(4)(e) provides that “a public authority may refuse to disclose information to the extent that. . .the request involves the disclosure of internal communications”. Since the information is an internal communication within DfT, we have concluded that regulation 12(4)(e) is engaged and have withheld information accordingly.
This exception is subject to the public interest test. The key public interest considerations we have taken into account are set out below, and we have also applied a presumption in favour of disclosure as required by regulation 12(2) of the EIRs.
Underlying this exception is the principle that public authorities should have the necessary space to think in private. The need for a ‘safe space’ is particularly relevant in considering the public interest in this case because the information covers a variety of live internal policy debates related to decarbonising the UK economy, which Government officials need to discuss and review. Disclosure of this information would affect this ‘safe space’ and releasing the information at this time would risk damaging the internal decision-making process.
In addition, we also consider that the requested information should not be disclosed in order to protect effective commercial discussions and decisions within the Government pertaining to scope of future policy development. Releasing such information now on future policy intention could damage the internal policy-making process and influence private sector investment decisions.
Against that, there are of course arguments in favour of transparency of policy discussions generally. These include increasing public accountability and allowing the public to assess and influence the quality of decision making on policies such as those in relation to decarbonising the UK economy. However, we have concluded that the Transport Decarbonisation Plan itself contains appropriate detail at this stage for the public to engage with our decarbonisation proposals and therefore that the public interest in disclosing the information is outweighed by the public interest in withholding the information."

I am appealing your decision on the following grounds:
Regulation 12(4)(e) provides that “a public authority may refuse to disclose information to the extent that. . .the request involves the disclosure of internal communications”. Since the information is an internal communication within DfT, we have concluded that regulation 12(4)(e) is engaged and have withheld information accordingly.

The information that I am requesting should not be classified as an internal communication. I am not asking for information which relates to matters which the Department has not yet decided to put in the public domain. You published Figure 2 as part of a White Paper and clearly must therefore stand by the analysis which underpins that chart. I am not asking for any detail surrounding how you came to the assumptions which underpin the chart or who derived them.

The Climate Change Committee publishes its assumptions in each of its carbon budget assessments and reports to Parliament. You require scheme promoters for investments you support to provide these and other assumptions for scrutiny. You appear to be proposing a different level of transparency for the DfT through the internal communications exemption claim. In the follow up response to my message you also point to examples (e.g. the Net Zero Strategy) where you have made available select variables such as the proportion of ZEVs in each category at different points in time. You have also made available the percentage of trips to be made by walking and cycling in towns and cities. It is therefore unclear why the specific information I have asked for is classified as internal communication whereas other 'select' information is not. Whilst I am grateful for your pointing towards various information which is in the public domain, it does not correspond to the content I have requested in my FOI.

You have also invoked the importance of a ‘safe space’ in relation to a ‘range of live internal policy debates’ as a means of outweighing the public interest: "Underlying this exception is the principle that public authorities should have the necessary space to think in private. The need for a ‘safe space’ is particularly relevant in considering the public interest in this case because the information covers a variety of live internal policy debates related to decarbonising the UK economy, which Government officials need to discuss and review. Disclosure of this information would affect this ‘safe space’ and releasing the information at this time would risk damaging the internal decision-making process. "

I respect the Department’s position that it should continually review the assumptions and policy positions which it holds. I am not however requesting any information about any on-going policy positions, I am requesting the assumptions that were used at the time of the production of the White Paper. As noted above, you felt that those assumptions were sufficiently robust and defensible to table the White Paper. The information I am requesting relates to the upper and lower bounds of uncertainty for the carbon pathways you have set out. The very nature of the curves (describing uncertain extremes) makes it clear that this does not represent a fixed Department policy as does your description of them on page 44 of the TDP.
There is no justification of which decision-making processes are being undertaken which the 'safe space' exemption applies to nor any explanation as to why the release of the specific information requested would violate that ‘safe space’ of the Department. As I note above, however, as the two curves which I am requesting data on do not represent a fixed DfT policy I still do not see how this would, in any case, render the safe space argument valid.

Further to this, it is apparent that the Department recognises the relevance of the assumptions made at the time of the TDP and is instructing National Highways to use them as part of its arguments about the environmental impacts of future road schemes (I refer here to para 1.5.8 in the following: https://infrastructure.planninginspector...).

Further to the above, it is impossible to see how any future discussions on any topic could apply to my request around point 3 which is to ask what assumptions were made which separate the upper and lower bound of uncertainty as we come out of Covid-19. The period over which those assumptions were made has now played out and so it seems entirely unreasonable to withhold the assumptions made and how they then carry forward into future years.

Finally, you wrote that “the requested information should not be disclosed in order to protect effective commercial discussions and decisions within the Government pertaining to scope of future policy development. Releasing such information now on future policy intention could damage the internal policy-making process and influence private sector investment decisions”.

As you may be aware, ICO guidance states that when applying this kind of exemption, an authority "must show that because [the information] is commercially sensitive, disclosure would be, or would be likely to be, prejudicial to the commercial activities of a person (an individual, a company, the public authority itself or any other legal entity)”. This response does not appear to have included such details, so as part of the internal review, if the exemption is upheld, please show how the release would be prejudicial to commercial activities, and of whom.

The information requested is an aggregate assessment of the proportion of miles driven by different categories of vehicles. It is impossible to see from that kind of aggregation of data what commercial decisions would be at stake. I contrast this with the % of ZEVs in the fleet which are included in the Net Zero Strategy table which you shared (p236) which is much more directly related to units of vehicles sold. Nothing which is being requested here appears to have any direct commercial implication. I further reinforce the point made earlier that the data does not pertain to a fixed policy position but an envelope and so should not be seen to be a definitive statement of DfT policy against which commercial decisions could be taken.

Finally, you conclude that the plan “contains appropriate detail at this stage for the public to engage with our decarbonisation proposals and therefore that the public interest in disclosing the information is outweighed by the public interest in withholding the information.” The Information Commissioner is clear that the public interest means the public good, not what is of interest to the public. I believe you have applied the latter interpretation whereas the information requested is for the public good as it relates to a transparent debate about what the plan could imply. The information is being used in supporting the work of National Highways in a public inquiry and yet be deemed by you not to be of public interest.

I am therefore asking that you revisit your initial response and release the information requested in the initial FOI.

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

Yours faithfully,

Greg Marsden

FOI-ADVICE-TEAM-DFT, Department for Transport

Dear Mr Marsden,

I am writing to acknowledge receipt of your request for an internal review of EIR response E0020915. We aim to respond on or before the 30th May 2022.

Regards,

Ivan Pocock
Information Rights Adviser, Information Rights (Data Protection and FOI) Team, Governance Division, Group Assurance and Digital Directorate

Department for Transport
3rd Floor, One Priory Square,
Hastings, TN34 1EA

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FOI-ADVICE-TEAM-DFT, Department for Transport

1 Attachment

 

Dear Marsden,

 

I am writing to advise you that we need to extend the deadline date for
reply to your internal review request. We now aim to respond on or before
the 29th June 2022. I appreciate this will be disappointing news but
please be assured that we are working to get a response to you as soon as
possible.

 

Regards,

 

Ivan Pocock

 

[1][IMG] Ivan Pocock 
Information Rights Adviser, Information Rights (Data Protection
and FOI) Team, Governance Division, Group Assurance and Digital
Directorate

3rd Floor, One Priory Square, Hastings, TN34 1EA       
[2]Follow us on twitter @transportgovuk 

 

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The information in this email may be confidential or otherwise protected
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and then delete it immediately, without printing or passing it on to
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References

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FOI-ADVICE-TEAM-DFT, Department for Transport

2 Attachments

 

Dear Mr Marsden,

 

Please refer to the attached letter.

 

Regards,

 

Ivan Pocock

 

[1][IMG] Ivan Pocock 
Information Rights Adviser, Information Rights (Data Protection
and FOI) Team, Governance Division, Group Assurance and Digital
Directorate

3rd Floor, One Priory Square, Hastings, TN34 1EA      
[2]Follow us on twitter @transportgovuk 

 

══════════════════════════════════════════════════════════════════════════

The information in this email may be confidential or otherwise protected
by law. If you received it in error, please let us know by return e-mail
and then delete it immediately, without printing or passing it on to
anybody else.
Incoming and outgoing e-mail messages are routinely monitored for
compliance with our policy on the use of electronic communications and for
other lawful purposes.

References

Visible links
1. https://www.gov.uk/government/organisati...
2. https://twitter.com/transportgovuk

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