Transport for London (TfL) have recently been consulting on their Transparency strategy. Their recognition of the need to improve on this key tenet of Open Government is very welcome and Involve were pleased to be collaborate with Open Rights Group, Campaign for Better Transport, and London Cycling Campaign in submitting this joint response:
Transport for London consultations
197 Blackfriars Road
London SE1 8NJ
By email to: email@example.com
6 March 2015
We also make specific recommendations in a number of areas where we believe service provision, accountability, decision-making, and the involvement of the public and stakeholder groups, would be improved with more effective transparency.
Our organisations, and local groups and members within our organisations, are also likely to respond with individual comments that may go into more detail about particular needs.
We believe the consultation documents don’t quite describe the importance and benefits of transparency in the correct terms.
They currently say:
By being open and accountable we:
Transparency is not simply about observation; nor is scrutiny simply a matter of evaluating prior decisions.
We would change and expand this description of TfL’s transparency agenda to make it clearer that the results of good transparency and effective scrutiny also include improvements to the decisions that result and the more effective involvement of the public in these decisions.
Our additions to this statement on the benefits of transparency (in bold) would be:
By being open and accountable we:
In addition to these benefits for the community and TfL, better transparency will also help the London Assembly in its job of scrutiny and will improve the questions it can ask and the dialogue it can have with TfL.
It is good to read of the intention to “Constantly analyse what our customers and users tell us are important to them”. We hope that this involves the engagement of citizens as well as stakeholders, to ensure the public interest (and what the public is interested in) is reflected, rather than just the views of interest groups.
Recommendations and principles:
Data is not neutral; what is collected, how it is collected, what is published, how it is published, what is presented and how it is presented will all affect the way that the data, services and government are perceived by the public.
Some groups, for instance pedestrians and cyclists, are more likely to be disadvantaged by gaps in knowledge and lower levels of data collection. In contrast, data on motor vehicles and public transport are increasingly created and collected through TfL business practices. Similar issues apply to data involving adults compared with children, and free modes that even the poorest people have access to (principally walking and cycling) compared with those that require payment.
These issues could lead to institutional biases unless carefully addressed in TfL policies for data collection and the process of deciding how it collects and uses data.
We believe that TfL should have a clear process for making and reviewing decisions about the types of data collected or created by its operations. In order to secure the public’s trust, this system needs to be transparent and include some neutral oversight.
Examples of where TfL should be heading with open data sets:
Recommendations for oversight and planning of data transparency:
Recommendations for collecting and publishing data types:
Recommendations for data formats:
We know that much of the research carried out in the process of making policy and deciding on different investments and projects is never published. There would be huge wider knowledge benefits in releasing more of the results of TfL’s research in full, under reusable licenses.
As a first step, TfL should publish and keep up to date a register of current research plans, including the brief, details of researchers and expected publication dates.
To widen what is available and to make better informed decisions about what research is needed, there should also be greater involvement of stakeholders in putting together commissioning strategies for research.
Evidence-based decision making is vital but, for it to also be credible not just factual data, but the use to which this evidence is put when making decisions, must be made available to be checked and tested. At the heart of this lies a need for more transparency in modelling.
TfL’s transport modelling forms the basis of many decisions, and underlies the value for money calculations for many projects. However, the structure of the model and the assumptions that go into it are not currently transparent, hampering the ability of stakeholders to examine the decision-making process, and preventing them from testing the credibility of this work.
In particular, stakeholder groups would like to be able to test different assumptions and different proposals on the model itself, but currently rely upon TfL’s staff and contractors to help with this when it is needed, and this assistance is only very rarely provided.
Examples of open modelling in Government:
An example of when a more open approach to modelling would have been of use is the recent decision to approve the new segregated cycle superhighways, sometimes called ‘Crossrail for Bikes’. At the TfL Board meeting on 4 February, when questioned about the £200 million cost disbenefit of the scheme and the accuracy of the modelling, saying they were ‘pessimistic’ in the sense that traffic impacts tended to be less bad than predicted.
At the GLA Transport Committee Meeting in December 2014, Caroline Pidgeon MBE AM (Chair) said of the models: “A lot of transport modelling seems to need to be updated. We have had in the past London Overground with huge suppressed demand. This current modelling does not seem to predict how many passengers are likely to use different modes.”
Similarly, Andrew Gilligan (Mayor’s Cycling Commissioner) said: “The modelling has often been too pessimistic in the past and you can see that by what it predicted compared to what has actually happened. It predicted, for instance, that the abolition of the Western Extension to the Congestion Charge Zone would cause between 8% and 12% more traffic in the Zone and a rise of 15% to 21% in congestion. The actual rise was 6%. It predicted a drop in traffic speeds of 6% to 12%. The actual drop was 3%. On one of the cycle schemes we have already done, the first fully segregated Superhighway stretch in Stratford High Street, it predicted delays of about a minute-and-a-half or a minute-and-a-quarter for bus services on that road. Actually, the delay has been negligible.”
We recognise that the current model is complex and multi-layered, but strongly urge TfL to begin the process of opening up modelling to more scrutiny.
Ultimately, a fully open and transparent model should be the aim, with any proprietary software replaced by open source programs, such as the examples given above.
The Transparency Strategy document acknowledges that responding to Freedom of Information (FOI) requests costs around £1m per year. A significant amount of this could be saved if the information was publicly available.
The Institute for Government ‘Whitehall Monitor 2014 Report’ shows that 14 of the 19 Whitehall departments responded to more than 90% of FOI requests. There is significant room to improve on the 89% being responded to within statutory deadlines.
Recommendations for Freedom of Information:
In conclusion, we hope these proposals are taken up, and that TfL seeks not merely to have an adequate programme of transparency, but to become a world leader in open data, open accountability, and open decision-making that involves the public and stakeholders at all levels.
Tom Harrison, Involve
Sian Berry, Campaign for Better Transport
Rosie Downes, London Cycling Campaign
Jim Killock, Open Rights Group