Water Fluoride Sample Data

Deborah made this Rheoliadau Gwybodaeth Amgylcheddol request to Albion Water Limited
You only have a right in law to access information about the environment from this authority

Roedd y cais yn rhannol lwyddiannus.

Dear Albion Water Limited,

I would like to request some information on water fluoride levels for a public health research study at the University of Manchester.

Please can you supply:

1. Water fluoride concentration sample data (consumer tap samples) for every Water Supply Zone within the regions that you supply water to, for every year from 2009-2020?

Please supply this in Mg of fluoride per litre, with the date of the sample, and the Water Supply Zone name and zone code, preferably as an Excel file.

2. GIS Shapefile maps showing the Water Supply Zone boundaries for every year from 2009-2020.

Many thanks in advance,

Yours faithfully,

Deborah Moore

Angela Cutler, Albion Water Limited

Deborah,

Thank you for your enquiry. You will receive a response on, or before, the 27th August.

Best wishes

Angela

Angela Cutler
Market Analyst

T: +44 (0)3300 580085
M: +44 (0)7831 261410
A: Harpenden Hall, Southdown Road, Harpenden, Hertfordshire AL5 1TE
W: albionwater.co.uk

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Angela Cutler, Albion Water Limited

1 Atodiad

Deborah,

Thank you for your enquiry. Albion Water has two water supply areas, in Oaklands Hamlet, Chigwell and Upper Rissington, Gloucestershire. For both areas we have a bulk supply from the incumbent water companies (Essex and Suffolk Water for Oaklands Hamlet and Thames Water for Upper Rissington). Neither area has fluoride added to the supply so any fluoride found in the water will occur naturally in soils and rocks.

Albion Water took on responsibility for Upper Rissington in 2014 and Oaklands Hamlet in 2016 (with regulatory sampling commencing in February 2017) so I can only provide our figures for these years onwards.

Our water quality results are attached.

We have reviewed the request for the GIS shapefiles and we consider that disclosure of this information could adversely affect national security or public safety, therefore under Regulation 12(5)(a) we have decided not to disclose this data. We consider that a significant risk exists that release of extensive information on the layout of our water supply network could give rise to a threat of criminal or terrorist activity leading to contamination of drinking water. We have noted:

1. The information could assist in the planning, preparation and undertaking of a terrorist or criminal attack through knowledge of the layout of the water supply network and locations of access to the water supply network and introduction of contamination.
2. The information could be aggregated with other information already known or in the public domain to determine how national utilities infrastructure relates to other critical infrastructure such as schools, hospitals and government departments as well as how services are provided to the general population.
3.The Information Commissioners guidance on national security, states that "relatively mundane information about primarily civil infrastructure could also be of use to terrorists and therefore could attract the exception provided by regulation 12(5)(a)".

We have concluded that the release of this information into the public domain could both assist in the planning, preparation or undertaking of an attack, or increase the risk or severity of an attack on the public water supply infrastructure and that this would constitute an issue of national security and public safety.

For these reasons, withholding of the information is reasonably necessary for national security and public safety and Regulation 12(5)(a) applies to allow us to withhold it.

Regulation 12(5)(a) enables us to withhold information provided the public interest in withholding it outweighs the public interest in it being disclosed. There is also a presumption in favour of disclosure.

We have considered the public interest in withholding and disclosing the information. We recognise that there is a public interest in transparency and accountability and also promoting understanding of environmental issues. We have taken account of the fact that information regarding the water supply network could be used by the public or interested parties to promote open knowledge of the water supply system and may be of interest to property owners, developers or buyers to understand proximity to assets or as part of a risk assessment process. However, we consider that disclosure of data in the form requested could aid or assist those who wish to do serious harm to the water supply network. This is inherently contrary to the public interest. We have concluded that on balance the public interest in this information being withheld is greater than it being disclosed.

If you have any questions regarding the decision outlined above please contact me on this email address ([email address]).

If you are dissatisfied with the handling of your request, you may request an internal review. Internal review requests should be submitted within 40 working days of the date of receipt of this email to [Albion Water Limited request email].

If you are dissatisfied with the outcome of the internal review, you may apply without charge to the Information Commissioner, who will consider whether we have complied with our obligations under the EIRs and who will require us to remedy any problems. You can find out more about how to do this and about the EIRS in general on the Information Commissioner's website www.ico.org.uk. Complaints to the Information Commissioner may be made via the link www.ico.org.uk/make-a-complaint/.

Best wishes

Angela

Angela Cutler
Market Analyst

T: +44 (0)3300 580085
M: +44 (0)7831 261410
A: Harpenden Hall, Southdown Road, Harpenden, Hertfordshire AL5 1TE
W: albionwater.co.uk

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Dear Albion Water Limited,

Please pass this on to the person who conducts Freedom of Information reviews. I am writing to request an internal review of Albion Water Limited's handling of my FOI request 'Water Fluoride Sample Data'.

Firstly, thank you for supplying the fluoride sampling data from 2014 / 2016. Please could you let us know who holds the data for the years prior to this?

In your response you have stated that:

“We have concluded that the release of this information into the public domain could both assist in the planning, preparation or undertaking of an attack, or increase the risk or severity of an attack on the public water supply infrastructure and that this would constitute an issue of national security and public safety."

We have already received GIS shapefiles illustrating Water Supply Zone boundaries from the following companies:

-Affinity Water
-Bristol Water
-Portsmouth Water
-South West Water
-Southern Water Services

We have also been advised by the Drinking Water Inspectorate that this information is available under EIR regulations, and that we should contact the water companies directly to obtain it.

Please can you explain why the assessment in your area differs from the other companies listed above and the DWI?

This information is essential to allow us to conduct publicly-funded (NIHR) research on the dental health effects of water fluoridation. I would like to ask you to re-consider the possibility of supplying the information under the EIR regulations.

Kind Regards,

Deborah Moore, The University of Manchester

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/w...

Angela Cutler, Albion Water Limited

Deborah,

Thank you for your enquiry.

For the Upper Rissington area the data would be available from Thames Water (pre 2014) and for the Oaklands Hamlet area the data would be available from Essex and Suffolk Water (pre 2016).

I will pass your request for an internal enquiry on to the relevant team and you should expect a response on or before Friday 23rd October.

Best wishes

Angela

Angela Cutler
Market Analyst

T: +44 (0)3300 580085
M: +44 (0)7831 261410
A: Harpenden Hall, Southdown Road, Harpenden, Hertfordshire AL5 1TE
W: albionwater.co.uk

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Angela Cutler, Albion Water Limited

Deborah

Further to my email of 28 August 2020, I can confirm that an internal review into the response provided to you on 21 August 2020 is being undertaken by the Group General Counsel, Ruth Jefferson, who will notify you of the outcome as soon as possible but no later than within 40 working days from the date your request was received (i.e. by no later than 23 October 2020).

Best wishes

Angela

Angela Cutler
Market Analyst

T: +44 (0)3300 580085
M: +44 (0)7831 261410
A: Harpenden Hall, Southdown Road, Harpenden, Hertfordshire AL5 1TE
W: albionwater.co.uk

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Ruth Jefferson,

3 Atodiad

Dear Deborah

Please see attached.

Kind regards
Ruth

Ruth Jefferson
Group General Counsel

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