16 August 2021
Mr Roger Bray
By email:
[FYI request #16244 email]
Dear Roger
Official Information Request – Copies of Submission Request
1. We refer to your official information request dated 29 July 2021 for information in
respect of the submissions received by the Management Agency during the July 2021
consultation in respect of the review of the Biosecurity (American Foulbrood Pest
Management Plan) Order 1998 (“
the Plan Order”).
Reasons for Difficulties in Fulfil ing Request
2. Your request as it is currently framed wil be very difficult to meet without substantial
collation or research. We briefly set out for your information below why your current
request wil be difficult to meet.
3. The information you have requested is not easily accessible as we would need to
extract each of the 415 submissions received from the SurveyMonkey platform and
further 20 submissions.
4. The information you have requested is difficult to collate as we would need to identify
and review each and every one of the 435 submissions received and redact the
information recorded below to protect respondents’ privacy. The submissions
contained beekeepers’ personal details, including, but not limited to, their names,
physical addresses, email addresses, and phone numbers. After this extensive
exercise, the submissions would need to be collated and provided to you in an
accessible format (which would require additional work to be carried out). By way of
example, we would need to go through all of the submissions one by one and
manually redact them to address the abovementioned privacy concerns.
5. We have calculated that it wil take approximately 40 hours to process your request.
Unfortunately, I am the only person trained to assess and respond to requests for
official information. Due to my existing workload, it would not be practicable for me to
fulfil your above-mentioned request (as it is currently drafted) as this would have a
detrimental impact on my ability to ensure the Management Agency can meet its
statutory obligations pursuant to the Plan Order.
If your Request Cannot be Amended
6. Unless your request is amended, we may have to refuse it under section 18(f) of the
Of icial Information Act 1982 (“
the OIA”), which applies where the information cannot
be made available without substantial collation or research.
7. Pursuant to section 18A of the OIA, we are required to consider whether fixing a charge
or extended the time limit would enable us to grant your request for information.
Unfortunately, for the reasons recorded above, we do not consider that either charging
you a fee nor extending the time limit would allow us to meet your request.
8. Please let us know before
5:00pm on Thursday 19 August 2021 whether you are
prepared to amend or clarify your request and, if so, how.
9. Notwithstanding the above, the Management Agency wil shortly be undertaking a
review of the abovementioned submissions, and a report wil be produced when the
review has been completed. We anticipate that this report wil be published in October
2021. This report wil include a summary of all of the submissions received and wil be
publicly released for your perusal and review.
10. Should you have any questions, please do not hesitate to contact us.
Yours Sincerely
Clifton King
National Compliance Manager
