Dear [Natural England]
I wish to complain about the information that you sent me in response to this request (RFI 3031). I request an internal review by NE of whether it has discharged its obligations under EIR.
Specifically, the paper NEB 49 13 is heavily redacted and contains little information about how the ‘Gate Zero’ process will work.
You have suggested that information has been redacted on two grounds:
1. Regulation 12(4)(e) – Internal Communications
I do not believe that you have applied the public interest test fairly or fully here. The invention of ‘Gate Zero’ seems to me to be a potentially illegal addition to the designation process which will harm the environment by reducing the number and coverage of notified and designated sites of nature conservation value. Protection of sites of nature conservation value is a matter of high interest to me, is a core duty of Natural England and is quite clearly a matter of public interest. As far as I am aware the redacted papers are the only source of information on this subject for a concerned taxpayer to learn what is happening. It is unreasonable to withhold this information. If this information is in the public domain elsewhere then please point me towards it, but I still request that you conduct an internal review of this redaction.
2. Regulation 12(5)(g) – environmental information
Since I suspect that the redacted parts of the paper may demonstrate that Natural England is weakening environmental protection of sites that qualify for designation or notification it is ironic that you cite ‘environmental protection’ as a reason for redaction – how wittily ironic! I believe that environmental protection will be enhanced by shining a light on the details of Gate Zero because Natural England’s plans are weakening that protection by delaying the notification of sites as SSSI. Therefore, it is unreasonable for NE to redact this information which might reveal that NE’s plans will harm the environment. I request that you conduct an internal review of this redaction.
And could you please check that what you sent me was in fact what you meant to send me as the numbering of sections and pages seems rather eccentric – could you please check?