Dear Sir/Madam,

FOI request: FOI-712

Thank you for your request dated 24/10/2023

Your request will be answered by 21/11/2023

If you have any queries about this request, please contact me, quoting the
reference number above.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [1]www.royalgreenwich.gov.uk

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Dear Sir/Madam,

Thank you for your request dated 24/10/2023, which was logged as a Freedom
of Information request FOI-712.

However, due to the nature of your request, it has been reclassified as an
Environmental Information Regulations request and now has a new reference
number, EIR-725.

Your request will be answered by 21/11/2023

If you have any queries about this request, please contact me, quoting the
reference number above.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [1]www.royalgreenwich.gov.uk

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From: foi <[Greenwich Borough Council request email]>
Sent: Tuesday, October 24, 2023 12:36 PM
To: 'Alex Clark' <[FOI #1040364 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI-712: Freedom of Information request - Correspondence with
developer

Dear Sir/Madam,

FOI request: FOI-712

Thank you for your request dated 24/10/2023

Your request will be answered by 21/11/2023

If you have any queries about this request, please contact me, quoting the
reference number above.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [2]www.royalgreenwich.gov.uk

ü Please consider the environment before printing this email

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Dear Sir/Madam,

Freedom of Information request:  EIR-725

Please accept our sincere apologies for a delay in providing a response to
your Freedom of Information request. We apologise for any inconvenience
this may cause. The service providing you with your response has been
chased today and they do remain committed to responding to your request as
soon as possible.

Yours sincerely,

Freedom of Information Team

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [1]www.royalgreenwich.gov.uk

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Dear Sir/Madam,

EIR request: EIR-725

Thank you for your request dated 24/10/2023 in which you ask;

Please can you supply me with all email correspondence between Greenwich
council and the developer Comer Homes Group over the past year.

Please supply emails sent to/from council officers as well as members of
the council cabinet.

Our response is as follows:

The information you have requested is exempt from disclosure under Section
39(1) of the Freedom of Information Act 2000, as it is information covered
by the Environmental Information Regulation 2004 (EIR).  The public
interest in applying this exemption is the same as that for EIR below.

Your request is clear and specific to the timeframe of the subject matter,
and there is therefore no requirement for the Council to seek refinement
or clarification of the request under Regulation 9 EIR.  We are however
unable to confirm that the requested information is held (as per EIR
Regulation 5), due to the cost involved in collating all this information
(please see estimate below). 

The information is excepted from disclosure under EIR Regulation 12 (4)
(b), which provides that "a public authority may refuse to disclose
information to the extent that – (b) the request for information is
manifestly unreasonable."  We consider the request to manifestly
unreasonable because disclosure under the request is likely to cause a
disproportionate cost or burden to the Council, even if an extension of
time for response is applied under EIR Regulation 7.

The time cost to the Council is estimated to be as follows:

  Activity Staff Reason
hours
A Determining whether you 1.5 Obtain all emails sent by Officers and
hold the information Members over the request period
B Locating the information, 17.5 Identify which emails may contain
or a document which may information relevant to the request by
contain the information reading through all of them
C Retrieving the 24.5 Confirming the emails relevant to the
information, or a request by highlighting those covered
document which may by the request
contain the information
D Extracting the 35 Summarising the record of emails and
information from a parts of emails which relate to the
document containing it request and excluding part of emails
which do not
E Considering whether other 49 Reviewing the highlighted emails /
exceptions apply parts of emails in D and assessing
whether exceptions apply like legal /
litigation privilege or confidentiality
(including consultation with any third
parties to establish adverse effect to
them
  Total 127.5

The above estimate is solely for the Planning Enforcement team
correspondence, based on dealing with similar requests in the past.  The
same exercise would need to be undertaken by Members Support for all
Member correspondence, and the internal legal team to consider the
exceptions, which would likely double the time estimated above.  There
would also be fees involved in work done on the disclosure by external
legal advisors, further adding to the overall cost of disclosure. The
Planning Enforcement team has limited resources as have most Local
Authorities across the country. Complying with the request would divert
resources away from enforcing planning obligations for the benefit of the
public. Due to the magnitude of this case it is particularly resource
intensive.

On this basis the Council's position is that the public interest in
withholding the information outweighs that in disclosure.

We note the presumption in favour of disclosure in Regulation 12(2) EIR. 
However since the public interest in withholding the information requested
considerably outweighs that in disclosure, we apply the exception despite
this provision, which is otherwise more appropriately used when arguments
on either side are more finely balanced.

If you are dissatisfied with our response you may express this
dissatisfaction to us in writing within 40 working days of receipt of our
refusal.  We will treat this as a request an internal review of our
decision under Regulation 11 EIR.  Internal reviews are undertaken by a
senior officer not involved in the preparation of the original response
and will consider your above request for information afresh in a fair and
impartial manner.  It will involve a thorough re-examination of our
original decision including a review of the outcome of the public interest
test.   It may amend or overturn our initial decision, or re-inforce it
with the support of additional exceptions.

Dissatisfaction can be expressed by writing to us on The Royal Borough of
Greenwich Compliance, 3rd Floor, The Woolwich Centre, 35 Wellington
Street, London, SE18 6HQ or email [1][Greenwich Borough Council request email] Your
request should set out why you are dissatisfied with the Council's
response, including your full name and correspondence address so that we
can write back to you. We will confirm receipt of your complaint in
writing and commence the internal review. We will aim to complete internal
reviews within 20 working days of receipt of your dissatisfaction.

If you are not satisfied with the outcome of the Internal Review, you may
apply directly to the Information Commissioner (ICO) for a decision. 
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. You can contact the ICO
by emailing [2][email address], or by post at Customer Contact,
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
SK9 5AF.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [3]www.royalgreenwich.gov.uk

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From: foi <[Greenwich Borough Council request email]>
Sent: Wednesday, November 22, 2023 4:43 PM
To: 'Alex Clark' <[FOI #1040364 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: RE: FOI-712 now EIR-725: Freedom of Information request -
Correspondence with developer

Dear Sir/Madam,

Freedom of Information request:  EIR-725

Please accept our sincere apologies for a delay in providing a response to
your Freedom of Information request. We apologise for any inconvenience
this may cause. The service providing you with your response has been
chased today and they do remain committed to responding to your request as
soon as possible.

Yours sincerely,

Freedom of Information Team

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [4]www.royalgreenwich.gov.uk

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Dear Sir/Madam,

Internal Review request: INT-909

Thank you for your request dated 29/11/2023

Your request will be answered by 27/12/2023

If you have any queries about this request, please contact me, quoting the
reference number above.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [1]www.royalgreenwich.gov.uk

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Dear Sir/Madam,

Internal Review on Freedom of Information request: INT-909

Thank you for your Internal Review request on the handling of your Freedom
of Information request. Please find the outcome attached.

If you are not content with the outcome of the Internal Review, you may
apply directly to the Information Commissioner (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. The Information
Commissioner can be contacted at: The Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment & Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8[1]www.royalgreenwich.gov.uk

ü Please consider the environment before printing this email

From: foi <[Greenwich Borough Council request email]>
Sent: Wednesday, November 29, 2023 2:44 PM
To: 'Alex Clark' <[FOI #1040364 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: INT-909: Internal review of Freedom of Information request -
Correspondence with developer

Dear Sir/Madam,

Internal Review request: INT-909

Thank you for your request dated 29/11/2023

Your request will be answered by 27/12/2023

If you have any queries about this request, please contact me, quoting the
reference number above.

Yours sincerely,

David White

Head of Information, Safety and Community Services

Directorate of Communities, Environment and Central

Royal Borough of Greenwich

*   3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ

8 [2]www.royalgreenwich.gov.uk

ü Please consider the environment before printing this email

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