26 August 2021
Mr Roger Bray
By email: [FYI request #16244 email]
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
2. Due to the substantial amount of work that would be required to research and collate
the information you have requested, we are refusing your request under section 18(f)
of the Of icial Information Act 1982 (“the OIA
Reasons for Difficulties in Fulfil ing your Request
3. We set out for your information below why your current request wil be dif icult to meet.
4. 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.
5. The information you have requested is dif icult 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.
6. 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, which are instrumental in the
elimination of American Foulbrood Disease in New Zealand.
7. If we were to comply with your request, this would likely result in the following
a. Failure to report to the Minister for Biosecurity (as required by the Biosecurity
b. Failure by me to lead Agency staff and contractors leading to the loss of
efficiency and effectiveness in the use of levy payer funds; and
c. Failure to present a fully consulted proposal in respect of the Plan Order to the
Minister for Biosecurity prior to its expiry on 1 April 2023.
Section 18A of the OIA
8. 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
Our consultation with you
9. We have also consulted with you in respect of your request, as required by section
18B of the OIA.
Our Letter to you dated 16 August 2021
10. In our letter to you dated 16 August 2021, we advised you that your request as it was
framed would be dif icult to meet without substantial collation or research, and we
invited you to amend your request.
11. In your email to us dated 19 August 2021, you advised us that you did not see the
need to alter your request in any way. In your feedback, you recorded that you
expected that the Management Agency used a “pro” version of the SurveyMonkey
platform that would allow us to provide you with copies of all of the abovementioned
submissions without disclosing the identity of the submit er.
Our Response to your Feedback
12. The Management Agency is subscribed to the “Team Advantage Plan” from
SurveyMonkey (“the Subscription
”). Unfortunately, the Subscription does not allow
us to provide you with copies of the submissions without identifying the identity or
personal details of the submit er. We acknowledge that the Subscription allows us to
extract of all of the submissions into an Excel spreadsheet, however the layout of this
spreadsheet would require significant formatting to be undertaken. By way of example,
we would need to manually adjust the width of every single row and column to ensure
that all of the text is visible to you. We calculate that there would be approximately
2,490 individual cells of data that would need to be manually reviewed by me.
13. Moreover, Excel does not have a “redact” function, so we would need to manually
delete individual “pieces of data” relating to submit ers’ private information. As you wil
appreciate, we would need to exercise extreme care when carrying out this exercise
to ensure that no private information is disclosed. Excel is an excellent platform for
displaying large quantities of numerical information; but unfortunately, it does not have
the capability to effectively display large quantities of text.
Time to Collate Information
14. In total, we estimate that it would take me 60 to 80 hours to undertake the
abovementioned exercise in Excel. For the reasons recorded at paragraphs 6 to 7
above, this would adversely affect the Management Agency’s operations and would
not be practicable in the circumstances.
15. In summary, our consultation with you has not resolved the dif iculty in collating your
Meeting Request in Alternative Way
16. While we cannot meet your exact request, 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. We wil endeavour
to provide this report to you as soon as it is available.
17. You have the right to seek an investigation and review by the Ombudsman of this
decision. Information about how to make a complaint is available at
or freephone 0800 802 602.
18. If you wish to discuss this decision with us, please feel free to contact me. Furthermore,
I am available to provide further assistance should you be wil ing to change or refine
National Compliance Manager