01/FOI/26/007777/G - Headlight FOI

Request:

Under the Freedom of Information Act 2000, I am requesting data regarding the enforcement of vehicle lighting offences, specifically focusing on non-compliant, aftermarket, or dazzling headlamps (e.g., retrofitted LED or HID bulbs in halogen housings).

Please could you provide the following information for the last six calendar years (2019, 2020, 2021, 2022, 2023, and 2024) broken down by year:

1. The total number of Traffic Offence Reports (TORs) and Fixed Penalty Notices (FPNs) issued for the following specific CJS offence code:

o RL89171: Use a motor vehicle on a road where the aim of the headlamp beam was used to cause undue dazzle / discomfort. 

2. If your electronic recording system allows for a keyword search within the free-text "officer notes" or "offence particulars" field without exceeding the Section 12 cost limit, please provide the number of the above offences (or general lighting offences) where the officer notes contain any of the following keywords:

o "LED"

o "HID"

o "Xenon"

o "Aftermarket"

o "Retrofit" 

3. The total number of Vehicle Defect Rectification Scheme (VDRS) notices or PG9 Prohibition notices issued specifically for non-compliant front headlamps. 

Response:

Humberside Police can confirm we do hold some of the information you requested however due to the way it is held in our systems it is not in an easily retrievable format. Therefore Section 12 of the Act applies.

With regards to question 3, to confirm whether a headlamp may be involved would require a manual check of over 2,600 records. A conservative estimate of 2 minutes per record would take this over 80 hours. Thereby far exceeding the appropriate limit of 18 hours.

Section 12 – Exemption where cost of compliance exceeds the appropriate limit.

s1(1) does not oblige a public authority to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the ‘appropriate limit’ (18 – hours).

Activities that may be counted within our time estimations are:

• Determining if the information is held;
• Locating the information, or a document containing it;
• Retrieving the information, or a document containing it; and
• Extracting the information from a document containing it.

The following have not been included within our calculations:

• The time spent identifying information to be exempted
• The time dedicated to the process of redaction.

Please take this as a refusal notice in accordance with section 17(5) of the Act which states; A public authority which, in relation to any request for information, is relying on a claim that section 12 or 14 applies must, within the time for complying with section 1(1), give the applicant a notice stating that fact.

When one part of a request triggers a S12 exemption, this applies to the whole of the request. However, although excess cost removes the force’s obligations under the Freedom of Information Act, as a gesture of goodwill, I have supplied information, relative to your request, retrieved or available before it was realised that the fees limit would be exceeded. I trust this is helpful, but it does not affect our legal right to rely on the fees regulations for the remainder of your request.

Please could you provide the following information for the last six calendar years (2019, 2020, 2021, 2022, 2023, and 2024) broken down by year:

1. We are only able to supply data from 2021, in accordance with retention policy. Data provided in the following table are for recorded offences where the offence date falls within the respective calendar year.

3. No Information Held. Our system does not have the relevant keyword search functionality to complete this question.
4. Section 12 exemption applies.

Please note that police forces in the United Kingdom are routinely required to provide information and statistics to government bodies and the recording criteria is set nationally. However, the systems used for recording these figures are not generic, nor are the procedures used locally in capturing the data. It should be noted that for these reasons this force’s response to your questions should not be used for the comparison purposes with any other response you may receive.