Dear Department for Exiting the European Union,

Under the terms of the Freedom of Information Act, please could I have a copy of analysis held by the Department which reflects on the economic consequences of Brexit, including analyses of differing regional or sectoral effects and the consequences of different outcomes.

It strikes me that this would, prime facie, be considered "statistical information", under the terms of the Act, and therefore exempt from section 35. For your reference, here is the ICO guidance on this exception from the s35 exemption.

"Statistical information used to provide an informed background to the government policy and decision… will usually be founded upon the outcomes of mathematical operations performed on a sample of observations or some other factual information. The scientific study of facts and other observations allows descriptive approximations, estimates, summaries, projections, descriptions of relationships between observations, or outcomes of mathematical models, etc to be derived.

A distinguishing feature of statistical information is that it is founded to at least some degree on accepted scientific or mathematical principles. Statistical information is therefore distinguished by being: (i) derived from some recorded or repeatable methodology, and (ii) qualified by some explicit or implied measures of quality, integrity and relevance."

It seems implausible that you could mount an argument that it is not in the public interest to publish this information. If, in the coming years, members of the public were to wish to make an investment - and were choosing between, say, London and Wales, it is surely unarguable that it would be in the public interest to release information to guide the decision.

That is certainly the settled view of government in other domains: it is personified in the existence of the ONS and codified in the UK Statistics Authority Code of Practise, of being "truthful and open about the statistics and their interpretation".

Release of this information is unlikely to prejudice the negotiation with the European Union. The full Treasury analysis produced during the referendum campaign already makes it clear that the view of officials is that No Deal would be awful.

Indeed, failure to release such analysis may prejudice the talks. The government position is that it is willing to end the negotiation, and accept "No Deal", but it is unlikely to be a credible threat so long as you are unable to produce any analysis suggesting that you now think a No Deal outcome is a non-disaster.

Yours faithfully,

Chris Cook

Dear DEXEU Freedom of Information Team Mailbox,

It has been widely reported that David Jones MP has stated, in a letter, that officials had “conducted analysis of over 50 sectors of the economy”.

Please could you supply me with the analysis to which he is referring.

Yours sincerely,

Chris Cook

Dear DEXEU Freedom of Information Team Mailbox,

Please note that a list of the documents to which I refer is enclosed here, in a letter from the secretary of state:

https://www.parliament.uk/documents/lord...

Happily, since they've already been defined, identified and indexed, I would be surprised if section 12 really could be engaged.

Yours sincerely,

Chris Cook

Dear DEXEU Freedom of Information Team Mailbox,

I thought it worth making a few points, incidentally, since I note you have engaged s22, s27 and s35 in your replies to other people on related requests.

First, I am pleased you have dispensed with s12.

Second, my requests are clearly, as I stated before, "statistical" in nature, so s35 cannot be engaged.

Third, if you wish to engage s22, I will need a clear statement of the intention, and it will need to have existed *prior to my request being made*.

As the ICO says: "The intention to publish must pre-date the request. This means that a public authority cannot, when it receives a request, attempt to give itself more time to provide the information by deciding to publish it in the future rather than provide it within the statutory time limit for answering a request."

Fourth, if you think revealing assessments of the economy are likely to prejudice our ability to negotiate with the EU (s27), I have some terrible news for you about the ONS and Eurostat. They literally publish monthly updates on how things are going. They publish data on exposure of industries to our decision to leave.

Furthermore, I would note that section 27 is a qualified exemption.

If I want to know whether to invest in fisheries or farms in Britain, it is clearly in the public interest that you should disclose which you envisage being the better bet. More investment into potentially successful industries and less into doomed ones is obviously in the public interest.

Furthermore, if it transpires that, for example, officials expect the auto industry would be devastated by leaving the European Union, the public interest in immediate release is much stronger than waiting - because the path dependencies involved in the negotiation are so strong: there are options open now that will not be in 2 years,

In general, the notion that the fact of a negotiation means the evidence underpinning judgments by ministers must be suppressed is obviously utterly bonkers.

Yours sincerely,

Chris Cook

Dear DEXEU Freedom of Information Team Mailbox,

This request is now overdue.

Yours sincerely,

Chris Cook