EIR - Investment Zones in Greater London [Oct 2022]

Your request

1. Please provide me with details of the potential locations of Investment Zones in Greater London.

2. Have any meetings taken place to discuss Investment Zones?

If so, please provide me with the following for each meeting in which Investment Zones have been discussed:

• a full list of attendees, including full names and titles as well as who the attendee represents
• a copy of the meeting agenda
• meeting notes and minutes taken during the meeting, as well as any briefing notes and papers
• any correspondence associated with the attendees, including debriefs of the meeting via email or other forms of communication.

3. Please provide me with any further official and unofficial correspondence relating to Investment Zones.

Our response

Investment Zones were announced as part of HM Government's Growth Plan 2022 on 23 September 2022. The government then published an expression of interest (EOI) process and guidance on Sunday 2 October with a deadline of noon Friday 14 October 2022.

On 14 October, the London Investment Zone EOI was submitted to government, including the following proposed locations:

• Euston and King’s Cross Innovation District
• London Riverside
• Old Oak West

As part of the Royal Docks, Beckton Riverside and Thamesmead Investment Zone proposal:

• Royal Docks
• Beckton Riverside and Thamesmead

As part of the Upper Lea Valley Investment Zone proposal:

• Edmonton
• North Tottenham
• Waltham Forest
• Whitgift and Queen’s Square (Croydon Town Centre)

The GLA is currently awaiting the government’s response to this EOI.

The GLA hosted a meeting on Friday with Local Authority Chief Executives, London Councils and Sub-Regional Partnerships. The following Chief Executives were invited:

1. Fiona Taylor (Barking & Dagenham)
2. John Hooton (Barnet)
3. Jackie Belton (Bexley)
4. Carolyn Downs (Brent)
5. Ade Adetosoyeade (Bromley)
6. Jenny Rowlands (Camden)
7. John Barradell (City of London)
8. Katherine Kerswell (Croydon)
9. Tony Clements (Ealing)
10. Ian Davis (Enfield)
11. Debbie Warren (Greenwich)
12. Mark Carroll (Hackney)
13. Sharon Lea (Hammersmith & Fulham)
14. Andy Donald (Haringey)
15. Patrick Flaherty (Harrow)
16. Andrew Blake-Herbert (Havering)
17. Tony Zaman (Hillingdon)
18. Niall Bolger (Hounslow)
19. Mandy Skinner (Hounslow)
20. Linzi Roberts-Egan (Islington)
21. Barry Quirk (Kensington & Chelsea)
22. Ian Thomas (Kingston)
23. Bayo Dosunmu (Lambeth)
24. Kim Wright (Lewisham)
25. Hannah Doody (Merton)
26. Colin Ansell (Newham)
27. Claire Symonds (Redbridge)
28. Mark Maidment (Richmond and Wandsworth)
29. Althea Loderick (Southwark)
30. Helen Bailey (Sutton)
31. Will Tuckley (Tower Hamlets)
32. Martin Esom (Waltham Forest)
33. Stuart Love (Westminster CC)

Please find attached the meeting invitation for the event and a copy of the notes that were made at the meeting.

We consider that part 3 of your request falls under the exception to disclose because it is
considered to be ‘manifestly unreasonable’ under regulation 12(4)(b) of the Environmental Information Regulation (EIR).

This provision allows public authorities to refuse requests which are obviously or clearly unreasonable or when the estimated cost of compliance is too great. In reaching this decision we have considered the views of the Upper (Information Rights) Tribunal in ‘Craven v IC & DECCC [2012] UKUT442 (AAC)’ in respect of the EIR exception under regulation 12(4)(b), the formal guidance issued by the Information Commissioner’s Office, along with Decision Notices regarding this EIR exception, such as FS505859262, amongst others, which all acknowledge that public authorities may use the fees regulations as the basis of considering the cost and time of complying with a request.

Many staff within our Good Growth Directorate (and other areas of the GLA) are likely to hold communications within scope of your request. In this instance, we have decided this request falls within the parameters of regulation 12(4)(b) and is manifestly unreasonable because of the considerable amount of time that would be required to collate and review the information.

Coordinating searches, extracting the relevant information and reviewing the information would place an unacceptable burden on resources and constitute an unreasonable distraction from normal work.

A public authority can only withhold information if the public interest in maintaining the
exception outweighs the public interest in disclosing the information. We are mindful of the
general public interest in transparency and accountability, and of the presumption in favour of disclosure and to read exceptions restrictively. We would consequentially have to spend a considerable amount of time reviewing each piece of information individually and consulting with a number of third parties to consider whether or not it would be exempt from disclosure.

Similarly, a large volume of information is likely to be administrative in nature. Where this information might be suitable for release under the EIR, the time and resources required to review this information would also be unreasonable given the limited benefit to the public debate on this matter.

On balance therefore, it is our view that the public interest in maintaining the exception in regulation 12(4)(b) outweighs the public interest in disclosure. In making this decision, we have taken account of the fact that government policy has only just recently been announced and that more information has and will continue to be published on the HM Treasury website.

I understand this response may cause frustration but it aims to ensure, as recognised in the guidance, that our responsibilities under the act do not distract from our other statutory
functions as a public authority.

When refusing a request for environmental information under regulation 12(4)(b) on the
grounds of cost, public authorities are required to provide advice and assistance and explaining how a request may be refined. However, this part of your current request is particularly broad and it is not clear what specific type of information you are most interested in in relation to Investment Zones.

You may wish to consider reducing the scope of your request by identifying particular themes or subjects for the correspondence in which you are most interested in, or by identifying specific correspondents by which we could refine our searches.

We have received a more focused request for communications between the GLA and the UK government concerning potential "Investment Zones" in the run-up to the Chancellor's 'fiscal event' on 23 September 2022. Attached is the information we hold within scope of this request for your information.

If you have any further questions relating to this matter, please contact us, quoting
reference MGLA290922-0176.