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Station Incident Response Plan

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Dear Network Rail Limited,

Please provide all documentation you hold relating to Station Incident Response Plans (SIRPs) as referenced in ATOC/GN033, including the standardised SIRP template.

Yours faithfully,
Connor A. Gurney

FOI, Network Rail Limited

Reference number: FOI2017/00972

Dear Mr Gurney

Information request

Your correspondence was received by Network Rail on 14th August 2017. I can confirm that your request is being processed under the terms of the Freedom of Information Act (FOIA). I will endeavour to respond to you as soon as possible and in any event by 14th September 2017.

On occasion we may need to consult with third parties about requests, in line with the recommendations in the Code of Practice issued by the then Secretary of State for Constitutional Affairs.

If you have any queries please do not hesitate to contact me.

Please remember to quote your reference number in all future communications.

Yours sincerely

Jonathan Mantle | Senior Information Officer
Freedom of Information | Legal Corporate & Commercial

Network Rail | 1st Floor | Willen Building | The Quadrant: MK
Elder Gate | Milton Keynes | MK9 1EN
Telephone: 01908 782405
Email: [Network Rail request email]
Web: http://www.networkrail.co.uk/foi/

FOI, Network Rail Limited

1 Attachment

Dear Mr Gurney

Please find attached a letter from Network Rail in response to your recent request for information.

Yours sincerely

Jonathan Mantle | Senior Information Officer
Freedom of Information | Legal Corporate & Commercial

Network Rail | 1st Floor | Willen Building | The Quadrant: MK
Elder Gate | Milton Keynes | MK9 1EN
Telephone: 01908 782405
Email: [Network Rail request email]
Web: http://www.networkrail.co.uk/foi/

Jonathan,

Thank you for your swift response. Though I absolutely understand your use of Section 31 and 38 of the Freedom of Information Act, I would like to contest your exemptions and ask that you review this request. First and foremost, you claim that a Section 38 exemption is justified in that "providing any information about our Station Incident Response Plans (SIRPs) would put terrorists in a better position to plan attacks".

Although I can see your logic and that specific information such as the location of rendezvous points for emergency personnel would offer those planning attacks an edge against the railway network (which I accept is at heightened risk due to the fact it consists of crowded spaces and forms part of the national infrastructure), I would argue that suitable redaction would counteract this risk.

I would also argue that information relating to preparedness for counter-terrorism threats is in the public domain as per ATOC/GN033 in the provided list of terrorist threats that station incident response planners must be prepared for ("suspect package, bomb threat, Marauding Terrorist Firearms Attack (MTFA), Chemical, Biological, Radiological, Nuclear (CBRN)") would itself be exempt from disclosure based on your logic as it could expose vulnerabilities to possible vectors of attack.

Considering the public interest test, I would argue first and foremost that, if a terrorist plans an attack on a station, they are highly likely to perform that attack irrespective of whether they have copies of the station's plan for responding to the atrocity they commit. I would again offer the opportunity to Network Rail to redact the documents as appropriate which I believe would counteract the risk.

Going on your quote from Chief Superintendent Des Stout — specifically the words "by the attacker remaining uncertain about the level of security" — I would contest that this is purely security through obscurity and offers very little security in practice. I would refer to my earlier statement in which I essentially state that an attacker will still commit an act of terrorism irrespective of whether they have details of station planning for the response to their atrocity.

As for your paragraph on secondary devices, I again invite you to redact appropriately the document(s) to ensure that the information released is not of benefit to those planning acts of terrorism against Network Rail stations. Though I would offer that secondary attacks have not been seen in the United Kingdom before, I accept that this is a possibility in an ever-changing dynamic. I would though say that releasing redacted information would again counteract the risk posed by disclosure.

You also mention that putting the documents into the public domain might "damage their effectiveness" since it is possible that "contributors would feel less inclined to put forward useful but contentious ideas for fear that to do so would create a public backlash." I would argue that by redacting the contributors names which you should do under Section 40 of the Act, any public backlash will not directly affect them or their ability to contribute.

Finally, in reference to the SIRPs template, I would apply the same principles as per the document(s) above and ask that you review my request thoroughly.

Best,
Connor A. Gurney

FOI, Network Rail Limited

Dear Mr Gurney

Our reference: FOI2017/01096

Thank you for your email of 14 September 2017 asking us to conduct an internal review of the response to your request.

The purpose of the internal review procedure is to provide a fair, thorough and independent review of the handling of your request under the Freedom of Information Act 2000.

We will endeavour to respond to your request for an internal review by 12 October 2017. We will write to you if an extension is required.

Please quote the above reference number in any future correspondence.

Yours sincerely

Colin Bendall
Information Officer – Compliance & Appeals
Freedom of Information Team
Network Rail
The Quadrant
Elder Gate
Milton Keynes
MK9 1EN

FOI, Network Rail Limited

Dear Mr Gurney

Our reference: FOI2017/01096

I am continuing to make enquiries in relation to your request for an internal review.

Please can I check one point with you. Your original request asked for "all documentation you hold relating to Station Incident Response Plans (SIRPs) as referenced in ATOC/GN033, including the standardised SIRP template."

When we processed your original request, we interpreted it as asking for (1) the standardised SIRP template and (2) the individual Station Incident Response Plans.

Please can you confirm if this is what you meant by your request, or whether you wanted any other information?

Yours sincerely

Colin Bendall
Information Officer - Compliance & Appeals
Freedom of Information Team
Network Rail
The Quadrant
Elder Gate
Milton Keynes
MK9 1EN

Colin,

Just to clarify, I'd like to request the standardized SIRP template and any documentation given to those using it, rather than individual plans. I understand your security concerns in relation to individual plans, and also feel these would be exempt due to Section 12 of the Freedom of Information Act.

Best,
Connor Gurney

FOI, Network Rail Limited

Dear Mr Gurney

Our reference: FOI2017/01096

Thank you for your email of 11 October 2017 confirming the scope of your request.

I am writing to advise you that I am still working on the internal review of the handling of your request.

I am therefore extending the time for response to 40 working days in line with the Information Commissioner’s guidance and will respond by 9 November 2017 at latest.

Yours sincerely

Colin Bendall,
Information Officer – Compliance & Appeals,
Freedom of Information Team,
Network Rail,
The Quadrant,
Elder Gate,
Milton Keynes
MK9 1EN

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