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Richard Clarkson

International Networks Analysis & Support

Department for Transport

Zone 1/24

Great Minster House

76 Marsham Street

London

SW1P 4DR

Direct Line: 44 (0) 20 7944 2764

Our Ref: E0006237

Web Site: www.dft.gov.uk

22nd April 2010

Dear Mr Todd,

Thank you for your request for information relating to the Department's aviation forecasting models, received on 23rd February.

You requested:

  1. Information about which departmental team or outside consultant is in charge of developing, revising and estimating the values for the input parameters in each of the models making up the Department's UK aviation forecasting and appraisal modelling suite, and whether there is any independent verification of them.

  1. Information about how frequently the model calculations are rerun with new data and what procedures exist for either reviewing public policy as a result of changes, or varying the input parameters to keep the output on track.

  1. Details of the programming languages or software platforms these models run within.

  1. A copy of the software code for the models, including inputs, in a form so that someone with access to the same software platforms could rerun them with minimum of effort.

I can confirm that the Department holds information relevant to all of these requests. I wrote to you on the 23rd March to inform you that as the subject of your request falls within the definition of 'environmental information' as set out in Regulation 2 of the Environmental Information Regulations 2004 ("the EIRs"), we have handled your request in accordance with that regime. I also informed you that because of the complex and voluminous nature of the request we were extending the time limit for responding to the response by 20 working days. In response to a further email from you on the 28th March I wrote to you again on 7th April to clarify that the reason for extending the deadline related to your requests 3 and 4 above. My letter of 7th April also provided the Department's response to your first two requests, and confirmed that we expected to be able to respond substantively to your requests 3 and 4 by 22nd April.

The Department's response to your requests 3 and 4 is below:

Requests 3 and 4

We are combining our response to these requests on the basis that they both appear to relate to the same broader request for information that would enable you or others to run the Department's UK aviation forecasting and appraisal modelling suite.

After careful consideration, we have decided to withhold the information you have requested under Regulation 12(4)(b) of the EIRs - the request for information is manifestly unreasonable. This exception applies in this instance because the costs of providing the information requested far outweigh the public interest in its disclosure, and because the work to obtain the information would unreasonably divert the Department's resources from delivering the public service it was set up to provide.

To provide you with a correctly functioning version of our forecasting suite, including all input files, in a form that would enable you or others to rerun with a minimum of effort would require our consultants who operate it to:

  1. install for you the necessary files in the correct manner on a suitable PC;

  1. fully train you to understand how to operate each piece of the modelling system, the complex interactions between model components and how to transfer outputs from one piece of the modelling system to another;

  1. write a detailed `step-by-step' user guide to producing all possible demand and CO2 forecasts, and appraisal calculations, that may be of interest to you, including `testing' of the user guide on a novice individual and subsequent improvements; and,

  1. provide an on-call support service to guide you on how to set up runs of particular interest to you, help resolve any running problems, and provide advice and guidance on how to interpret model results for all possible outputs that might be of interest to you.

It would be excessively expensive to provide the files, necessary advanced transport modelling training, a user guide, and provision of on-call support, to you (and even more so to make such a facility available to each and every stakeholder who wished to undertake new model runs).

This is because, as you have correctly identified in your request, the Department's aviation forecasting suite comprises many models, written in a variety of software languages, all of which have to be set up, interfaced and operated correctly to produce the forecasts (and economic analysis) we report. For example, the National Air Passenger Allocation Model (NAPAlM), one part of the forecasting suite, is a highly complex tool, written in C++ programming language, which requires specialist skills to operate, understand, and integrate (via another programming language) with other parts of the suite.

Under the EIRs there is a presumption in favour of disclosure. Therefore, in applying this exception, we have considered whether the public interest in favour of disclosure outweigh the costs. We identified the following key factors potentially favouring disclosure:

      1. It could further participation in the public debate; and

      2. It could promote accountability and transparency in the decisions taken by public authorities.

We have concluded, however, that the release of the information requested would only further the public debate if it were accompanied by the significant additional support detailed above. Providing this level of support would require the Department to incur excessively large costs. Even providing the information requested and without any training, user-guide or additional back-up support would require the Department to incur a significant cost. The public interest in favour of releasing the information in a raw form would also be weaker given our conclusion that the information would be meaningless in the absence of this additional support.

We believe that our long-standing policy on access to our aviation forecasting and appraisal suite, which avoids excessive costs, can provide you with meaningful access to the information you request.

The Department considers requests for alternative model runs from those who wish to see the effect of inputs significantly different from those we have used. The timing and scope of such model runs would depend on the availability of resources or other constraints, and would be conditional on the requesting stakeholder meeting the costs of DfT commissioning the consultants who would operate the model and, on our behalf, be involved in providing detailed technical explanations of the workings and outputs. The Department does not charge stakeholders for access to the modelling software itself. Many stakeholders have made use of this access arrangement in recent years. If you would also wish to make use of this arrangement, please contact me at the above address.

Furthermore, if you require information about our forecasting and appraisal framework that is not already available in our comprehensive report `UK Air Passenger Demand & CO2 Forecasts', please contact me and I would be happy to oblige. In particular, your original request notes that the forecasts presented in UK Air Passenger and CO2 forecasts, 2009 are given in non-computer readable format. We would be happy to provide these tables in a computer readable format if that would be helpful.

On balance we have concluded that because the costs of disclosing the information you have requested far outweigh the benefits, the public interest is best served by non-release.

If you are unhappy with the way the Department has handled your request or with the decisions made in relation to your request you may complain within two calendar months of the date of this letter by writing to me at the above address. Please see Annex A attached for full details of DfT's complaints procedure and your right to complain to the Information Commissioner.from [department] you may ask for an internal review. You should contact [name of official and address] if you wish to complain

Yours sincerely,

Richard Clarkson

Annex A

Your right to complain to DfT and the Information Commissioner

You have the right to complain within two calendar months of the date of this letter about the way in which your request for information was handled and/or about the decision not to disclose all or part of the information requested. In addition a complaint can be made that DfT has not complied with its FOI publication scheme.

Your complaint will be acknowledged and you will be advised of a target date by which to expect a response. Initially your complaint will be re-considered by the official who dealt with your request for information. If, after careful consideration, that official decides that his/her decision was correct, your complaint will automatically be referred to a senior independent official who will conduct a further review. You will be advised of the outcome of your complaint and if a decision is taken to disclose information originally withheld this will be done as soon as possible.

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

 

 Information Commissioner's Office
 Wycliffe House
 Water Lane
 Wilmslow
 Cheshire
 SK9 5AF

Available at: http://www.dft.gov.uk/pgr/aviation/atf/co2forecasts09/co2forecasts09.pdf