Published on March 11, 2015

Improving Transparency in Transport for London

Open government

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:










PDF version here

Transport for London consultations
Palestra House
197 Blackfriars Road
London SE1 8NJ 

By email to:

6 March 2015

Dear Sir/Madam,

Joint statement from Campaign for Better Transport, London Cycling Campaign, Open Rights Group and Involve in response to Transport for London’s transparency consultation=

We are writing this letter as a joint response from our organisations to the Transport for London (TfL) consultation on transparency, which ran until 8 March 2015. We welcome the opportunity to contribute to this process and to set out, briefly, the principles that our organisations believe TfL should be following in developing its strategy for transparency. 

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.

  1. Scope of the strategy

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:

  • Enable our stakeholders to hold us to account
  • Deliver better value for money
  • Help businesses, non-profit organisations, academics and others make transport in London better.

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:

  • Enable our stakeholders and the wider public to hold us to account, and examine our evidence base
  • Deliver better value for money and make better decisions that benefit the whole community
  • Help businesses, non-profit organisations, academics and others contribute to our decision-making, carry out independent studies and interrogate how we came to our conclusions
  • Help inform and empower the public, which in turn can contribute to more cohesive community relations, more active and trusting citizens and more effective public services.

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:

  • The benefits of transparency should be stated to include better decision-making and the empowerment of the public to get involved in this process.
  • The list of headings given in the consultation document don’t cover all the relevant aspects of transparency and we would like to see new sections to cover public health and safety, and participation in decision making.
  • The principles behind the strategy should also much more closely follow those from the Government’s Public Sector Transparency Board, ( Public Data Principles. Public Sector Transparency Board,  2012) which include strong commitments to open data,licensing and standards, as well as the timely release of data and the promotion of its re-use for the public benefit.
  1. Transparency in data collection and release

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: 

  • The city of Amsterdam has an award-winning open data programme with a huge number of datasets, many live, available.
  • The Norwegian government is a leading proponent of open decision-making, and makes government documents – including emails – available for access as soon as they are produced, received or transmitted by any central government agency unless there is a legal restriction). [More about Norway’s policies: and-information-integrity-norway]

Recommendations for oversight and planning of data transparency:

  • We recommend a panel is formed to continuously review the implementation of the Transparency Strategy, and to review the ongoing collection, use and release of data. This should include lay representatives as well as key stakeholders from the re-use community, including businesses and campaign organisations, as well as the London Assembly.
  • To add to the range of data available, stakeholders such as IT companies, mobile phone providers and cycling/walking groups themselves should also be involved in devising and collecting new datasets

Recommendations for collecting and publishing data types:

  • TfL should have a policy of full transparency on what data exists currently, including clear reasons for why some of it is not released (e.g. data protection).
  • Traffic counts are a key dataset that is currently not made available in the most useful or accessible way. The data should include APIs of all recent data, as well as counts of non-motorised traffic and pedestrians.
  • More and more accurate walking and cycling data should be collected, including robust methods for collecting statistical data on travel by children.
  • Data on junction signalling regimes and signal timings should be available. The signalling regime for all junctions should be published, with live data (or representative historical data sets) available to show when there are variations from the regime in place, and to enable modelling studies by academics and others.
  • To aid accountability, we also want to see data (and related documents) that led to decisions being made released promptly, including briefs to designers of schemes, business cases for different policies and projects, staff and organisational maps, decision process diagrams, meeting minutes and even emails.
  • More TfL meetings should be webcast, not just meetings of the Board.

Recommendations for data formats:

  • TfL currently lacks an accessible way of seeing what data is available. An index or user-friendly publication scheme, including a search option within the data/documents is vital to make accessing the data simple and easy
  • This interface also needs to offer a choice of formats for how to access it. PDF releases are common currently, but are not good practice.
  • More TfL data, especially on operations, needs to be live data provided via APIs, so that expert end-users and other third parties can produce their own apps.
  • In addition, TfL should produce its own presentation of operational data that is human-readable, for the general public. The London cycle hire scheme is already a good example of where both these options have been provided, giving end users a choice of official apps, in addition to a wide choice of other ways to find out about the scheme through independent apps.
  • Publicly accessible, graphic presentations of key data and statistics available from underlying data would improve the visibility of the information and help create interest among potential re-users. This would also ensure members of the public without the skills, time or confidence are able to hold TfL to account.
  1. Transparency in research

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.

  1. Transparency in modelling

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:

  • The Department for Transport is making moves to open future versions of the National Transport Model for external examination.
  • While this doesn’t include opening up the current model, it shows the worth of making sure future developments are planned with open access in mind, for example by specifying open source software rather than having the finished product restricted under proprietary licences.
  • The OBR/Treasury macroeconomic model, which is open, with the code available for anyone to see. This has resulted in effective scrutiny by Friends of the Earth.
  • MATSim is an example of an open source program used to implement large-scale transport simulations, which has been employed by many authorities around the world, including the whole of Switzerland, and cities in Germany, South Africa, Canada and Japan.
  • The freely available nature of the program makes it easier for authorities to release data that can be interrogated to test different scenarios and assumptions.

4.1 The limitations of current models

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.”

4.2 The need to open up modelling to scrutiny

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.

  1. Transparency in responding to Freedom of Information

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:

  • TfL should follow the example of the Department for Transport and publish to its public website all data it releases via FOI.This would likely save money in avoided duplicate requests.
  • TfL should open to scrutiny the reasons some requests aren’t responded to.

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.

Yours sincerely,


Tom Harrison, Involve

Sian Berry, Campaign for Better Transport

Rosie Downes, London Cycling Campaign

Jim Killock, Open Rights Group





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