Transport Scotland infrastructure deployment, safety protocols and environmental oversight of 5G, LED lighting and smart roads: EIR release

Information requested

5G Infrastructure & Deployment Oversight

1. Documents outlining the current approach to 5G infrastructure deployment on public assets (e.g. lampposts, signage, CCTV poles), including any guidance, frameworks, or implementation notes.

2. Names and roles of individuals or departments involved in coordinating 5G installations across trunk roads or public infrastructure.

3. Records relating to public engagement, consultation, or community feedback regarding 5G rollout.

4. Any health or environmental reviews conducted in relation to 5G installations, particularly near schools, care homes, or residential zones.

LED Street Lighting – Technical & Environmental Oversight

1. Technical specifications of LED units installed on trunk roads, including manufacturer, model, emission spectrum, and control protocols.

2. Details of CMS (Central Management System) providers and installers contracted for LED deployment.

3. Any documentation relating to lighting impact on human health, wildlife, or ecological systems.

4. Correspondence or guidance received from UKHSA, Public Health Scotland, or other relevant bodies regarding LED safety or environmental considerations.

Smart Roads & Data Handling

1. Overview of smart road infrastructure currently active or planned, including any embedded sensor, telemetry, or data collection features.

2. Documentation outlining the lawful basis for data processing associated with smart infrastructure, including privacy impact assessments or data-sharing agreements.

3. Names of any third-party contractors or data processors involved in smart road operations.

Response

As the information you have requested is 'environmental information' for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

5G Infrastructure and Deployment Oversight

Some of the information you have requested is available from 5G and public health: position statement - gov.scot and https://www.gov.scot/publications/foi-18-03634/ and https://www.gov.scot/publications/foi-19-00273/ . Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

Under an exception at regulation 10(4)(b) of the EIRs, a public authority may refuse a request for information if it is 'manifestly unreasonable'. The Scottish Information Commissioner's guidance on the regulation 10(4)(b) exception at: http://www.itspublicknowledge.info/Law/EIRs/EIRsExceptions.aspx says that there may “be instances where it is appropriate for the Commissioner to consider the proportionality of the burden on the public authority in terms of the costs and resources involved in dealing with a request when considering the application of this exception”.

It may be helpful to explain that when a request for information such as copies of all internal communications, details of any meetings and minutes of such meetings is received we run searches using key words used in that request. In this case, using key words such as “"5G infrastructure" AND ("public assets" OR "street furniture" OR lamppost* OR signage OR "CCTV pole*" OR "urban infrastructure") AND (guidance OR framework OR "implementation note*" OR policy) and 5G installation" AND (health OR environmental OR "impact assessment" OR "risk review") AND (school* OR "care home*" OR "residential zone*" OR "sensitive location*", resulted in more than 330 documents being identified. Each of these documents would then have to be analysed to ensure they were within scope of your request which would impose a significant burden on the authority and would take an unreasonable proportion of time and resources away from other functions. For these reasons, we consider that your request is manifestly unreasonable and so we are refusing it under regulation 10(4) (b).

As the exception is conditional we have applied the 'public interest test'. This means we have, in all the circumstances of this case, considered if the public interest in disclosing information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about 5G Infrastructure & Deployment Oversight including:

1. Documents outlining the current approach to 5G infrastructure deployment on public assets (e.g. lampposts, signage, CCTV poles), including any guidance, frameworks, or implementation notes.

2. Names and roles of individuals or departments involved in coordinating 5G installations across trunk roads or public infrastructure.

3. Records relating to public engagement, consultation, or community feedback regarding 5G rollout.

4. Any health or environmental reviews conducted in relation to 5G installations, particularly near schools, care homes, or residential zones.

This is outweighed by the public interest in ensuring the efficient and effective use of public resources by not incurring excessive costs when complying with information requests.

You may however wish to consider reducing the scope of your request in order to make it manageable. For example, as some of the keywords provided are quite generic, you could provide more specific information on the subject matter you are interested in as this would allow us to limit the searches that would require to be conducted. In addition, the combination of keywords also identify documents that are potentially out of scope and not what you require. You may also find it helpful to look at the Scottish Information Commissioner's 'Tips for requesting information under FOI and the EIRs' on his website at: http://www.itspublicknowledge.info/YourRights/Tipsforrequesters.aspx

LED Street Lighting – Technical & Environmental Oversight

Question 1 - Technical specifications of LED units installed on trunk roads, including manufacturer, model, emission spectrum, and control protocols.

Response

The current Trunk Road lighting asset contains LED lighting units from a variety of manufacturers, utilising various differing models dependant on the specific needs of the installation. Table 1 below gives information on current manufacturers and models, emission spectrum and control protocols collated from our Network Maintenance Contractors.

Table 1

Manufacturer	Model	Colour Temperature (K)	Control
CU Phosco	P855-288	4000	Photocell/CMS/Timeswitch
CU Phosco	FL800D	4000	Photocell/CMS/Timeswitch
CU Phosco	P510	4000	Photocell/CMS/Timeswitch
DW Windsor	Sabre	4000	Photocell/CMS/Timeswitch
Designplan	D863	4000	Photocell/CMS/Timeswitch
Designplan	D864	4000	Photocell/CMS/Timeswitch
Signify	Luma 1	4000	Photocell/CMS/Timeswitch
Signify	Luma 2	4000	Photocell/CMS/Timeswitch
Signify	Clearway	4000	Photocell/CMS/Timeswitch
Signify	MiniLuma	4000	Photocell/CMS/Timeswitch
Signify	Lumistreet Medium	4000	Photocell/CMS/Timeswitch
Signify	LumiStreet Large	4000	Photocell/CMS/Timeswitch
Thorn	StyLED	4000	Photocell/CMS/Timeswitch
Thorn	LED	4000	Photocell/CMS/Timeswitch
Thorn	R2L2	4000	Photocell/CMS/Timeswitch
Urbis	Axia	4000	Photocell/CMS/Timeswitch
Urbis	Neos	4000	Photocell/CMS/Timeswitch
Urbis	Ampera Midi	4000	Photocell/CMS/Timeswitch
Urbis	Ampera Maxi	4000	Photocell/CMS/Timeswitch

Question 2 - Details of CMS (Central Management System) providers and installers contracted for LED deployment.

Response

Transport Scotland Network Maintenance Contractors are responsible for the provision of lighting Central Management System (CMS) equipment across the Trunk Road Network. CMS providers with equipment currently installed across the Trunk Road Network are as follows:

1. Signify Citytouch

2. Signify Interact

3. Lucy Zodion Vizion

4. Schreder EXEDRA

Question 3 - Any documentation relating to lighting impact on human health, wildlife, or ecological systems.

Response

While our aim is to provide information whenever possible, in this instance Transport Scotland does not have the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. However we would guide you to the ILP (Home | Institution of Lighting Professionals) and LED manufacturer websites, as well as the European Commission Scientific Committee website (Scientific Committees - European Commission), for further information.

Question 4 - Correspondence or guidance received from UKHSA, Public Health Scotland, or other relevant bodies regarding LED safety or environmental considerations.

Response

Transport Scotland does not hold correspondence or guidance from UKHSA, Public Health Scotland, or other relevant bodies regarding LED safety or environmental considerations. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs but would guide you to the ILP (Home | Institution of Lighting Professionals) and LED manufacturer websites, as well as the European Commission Scientific Committee website (Scientific Committees - European Commission), for further information.

Smart Roads & Data Handling

1. It may be useful to clarify that we have defined “smart roads” as being the use of technology to collect data on the performance of the road network and use this information to inform drivers. This is distinct from the “smart motorways” used in some locations in the UK that involve the hard-shoulder being available to all traffic at certain times. This arrangement is not used in Scotland.

The Traffic Scotland service, provided by Transport Scotland, uses two types of technology to collect data relating to traffic volumes, classification and speeds. Sensors, including inductive loops, in carriageways are physical means to undertake this detection and have been used for many years. Traffic Scotland is now also using data supplied by connected vehicles and devices in order to measure traffic speeds, which is used to ascertain where congestion is occurring on the trunk road network.

2. All data used by Traffic Scotland as described in response to Q1 does not identify any individual, therefore privacy impact assessments and data sharing agreements do not need to be in place.

3. In regard to the “smart roads” definition described in 1. above, three contractors are involved in operations under contract to Transport Scotland. These are:

• Mobility IBI Egis (Mobiie) Limited
• Amey OW Limited
• Cubic Transportation Systems Limited

These contractors subcontract certain elements of their service delivery to a number of other organisations.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.