Details of Miniature/Indoor ranges
Dear British Army,
I would like to request the following information with regards to miniature ranges, indoor ranges and all other ranges suitable for shooting .22RF calibre rifles. This is to include those at Army Reserve Centres, Cadet Forces' 'Weekend Training Centres' and Cadet Forces' 'Detachments'.
1) A list of all miniature/indoor ranges.
2) The address/location of all miniature/indoor ranges
In the event that you do not wish to disclose the exact address due for security or other concerns, then the name of the building/centre and the town they are in would be sufficient.
Yours faithfully,
Richard Stebbings
Dear Mr Stebbings,
Your request has been logged under our reference 2021/11488 and the target date for response is 05/11/2021.
Yours sincerely
DIO Secretariat
Good Afternoon,
Please see attached a response relating to your Freedom of Information
request dated 8 October 2021.
Kind Regards,
DIO Secretariat
Defence Infrastructure Organisatiom
Dear British Army,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of British Army's handling of my FOI request 'Details of Miniature/Indoor ranges'. My request for a review is based on the following four points.
1. Duty to Confirm or Deny.
I note that you have not confirmed or denied whether the authority holds this information, and have not applied an exemption that would remove this obligation. As you may be aware, Section 1(1) of the FOI Act (https://www.legislation.gov.uk/ukpga/200...) states that "Any person making a request for information to a public authority is entitled to be informed in writing by the public authority whether it holds information of the description specified in the request". Furthermore, a public authority seeking to rely on section 26(3) must be able to explain how confirming or denying that information of a given description is held could pose a risk to defence matters or the safety of troops.
2. The Prejudice Test.
Both Section 38 and Section 26 are qualified exemptions. Following the ICO's guidance, you as the authority are obliged to provide details of a prejudice test and demonstrate the causal link between disclosure of the information and harm to an individual. Please provide full details of the prejudice test.
3. The Public Interest Test
Both Section 38 and Section 26 are qualified exemptions. Following the ICO's guidance, you as the authority are obliged to conduct a public interest test when applying this exemption. Please provide full details of the public interest test.
4. Disclosure would not bring new information to the public domain.
a) Full addresses of Army Reserve Centres and Cadet Force unit/Detachment locations is readily available in the public domain via a simple google maps search for 'Army Reserve Centre', 'Army Cadets', 'Sea Cadets', 'Air cadets' etc, as well as being listed publicly on the official websites for the Army Cadets, Air Cadets and Sea Cadets (www.armycadets.com, www.raf.mod.uk/aircadets/ and www.sea-cadets.org/units/ respectively). I would just like confirmation of which of these have range facilities.
b) You have previously responded to a number of FOI requests entitled 'Provision and Usage of Indoor Ranges within XXXXX RFCA Area', FOI ref 2020/13021. In your response you provide details of the amount of ammunition fired and a FULL ADDRESS of the range. Clearly there is no Defence nor Health and Safety inplications if you have readily released some of this information before. This new request just wants confirmation of the addresses for ranges not already disclosed under the previous FOI requests (FOI 2020/13021).
A full history of my FOI request and all correspondence is available on the Internet at this address: http://www.whatdotheyknow.com/request/de...
Yours faithfully,
Richard Stebbings
Dear Mr Stebbings,
Your email of 23 November 2021 has been passed to the Ministry of Defence (MOD) Information Rights Compliance Team as we are responsible for the investigation of all complaints about the processing of requests made under the Freedom of Information (FOI) Act 2000 to MOD.
The letter sent to you on 5 November 2021 by the Defence Infrastructure Organisation, on behalf of MOD, advised you that the Department held information in scope of your request (FOI2021/11488) but that it was considered that it fell within the scope of qualified exemptions provided for at sections 26 (Defence) and 38 (Health and Safety) of the Act. The response went on to explain that it was necessary to decide whether, in the circumstances of the case, the public interest in maintaining these qualified exemptions outweighed the public interest in disclosure and that more time was required to do this. You were advised that the target for completing this consideration and providing a substantive response to your request was 6 December 2021.
In cases where a public authority considers it necessary to consider the application of exemptions subject to a public interest test (PIT), the Act requires the authority to give notice of this fact within the first 20 working days of processing in order to meet the requirements of section 10(1) of the Act. Where the consideration of the public interest cannot be completed within this time, the Act obliges the authority to reach its decision "within such time as it reasonable in the circumstances". The Information Commissioner's Office, in its good practice guidance, considers that in cases where the public interest considerations are exceptionally complex it may be reasonable to take longer but that, in their view, in no case should the total time exceed 40 working days. I can advise that the estimated date for response provided in the letter of 5 November meets this best practice guidance.
Taking these factors into consideration, I am satisfied that the letter provided to you on 5 November met the requirements of the Act.
The substantive response which will be issued following completion of the public interest considerations. If you are dissatisfied with the substantive response when it is provided, please contact us again and we will conduct a formal internal review. Please note, we have not made any assessment of the validity of the exemptions being considered in this case, as doing so would disrupt or delay the processing of your request.
As the letter advised, you may raise your complaint directly to the Information Commissioner under the provisions of Section 50 of the Freedom of Information Act. Please note that the Information Commissioner will not normally investigate your case until the MOD internal review process has been completed. The Information Commissioner can be contacted at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Further details of the role and powers of the Information Commissioner can be found on the Commissioner's website at https://ico.org.uk/.
Yours sincerely,
MOD Information Rights Compliance team
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