Hi Team
Apologies, see below the response
TfL Ref: FOI-3065-2324
Thank you for your request received by Transport for London (TfL) on 27 November 2023 asking for information about a CCTV camera outside Lee High Road.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy. I can confirm we hold the information you require.
However, your request is being refused under Regulation 12(4)(b) of the EIR on the basis that it is ‘manifestly unreasonable’. Please see the rationale set out below.
We have received a large number of requests from different applicants asking for the exact same information in respect of different cameras. TfL has been refusing to release any information that would allow any of our ‘Digital Traffic Enforcement System’ cameras to be identified given the widespread instances of vandalism that some of these cameras have been subject to since the expansion of the Ultra Low Emission Zone (ULEZ). The rationale for this is as set out under a previous request for similar information, published on our website here:
https://tfl.gov.uk/corporate/transparency/freedom-of-information/foi-request-detail?referenceId=FOI-0970-2324 If the exceptions cited in the reply above were only ever applied to requests for information about the ANPR cameras used to enforce ULEZ, but not other cameras on the road network operated by TfL, then that would defeat the purpose of the exceptions applying – i.e. if that were the approach, then any time a request was refused then this would, in effect, identify our ANPR cameras. Therefore, the exceptions apply to all of our road camera infrastructure, so that the specific cameras used to enforce ULEZ cannot be distinguished from other cameras via FOI / EIR requests.
The use of the exceptions cited in the reply above have been challenged under Internal Review by other applicants, and the result of those reviews were that the use of the exceptions were upheld. In turn, an applicant has subsequently lodged an appeal on three separate occasions with the Information Commissioner’s Office (ICO) which is currently being considered by that body. The ICO will determine whether or not it agrees with TfL’s reliance on these exceptions. In the meantime, TfL stands by its use of the exceptions.
Given the above, TfL now considers that any current and future requests asking for information on the make and models of our roadside cameras be exempted as ‘manifestly unreasonable’. There is no public benefit in rehearsing the same arguments that are already before the ICO. As such, we believe that the current series of requests, which have an identical template-style wording and therefore appear to be part of a co-ordinated campaign, are ‘manifestly unreasonable’ because they represent:
Frequent or overlapping requests
Unreasonable persistence on matters which have either been resolved or are already before the Information Commissioner
Appear to lack serious purpose or value
Appear designed to cause disruption and disproportionate burden
We do not believe that the greater public interest is served by TfL considering each such case on an individual basis while the matter remains before the ICO.
Please see the attached information sheet for details of your right to appeal.
Yours sincerely,
