Select Committee on Public Administration Memoranda


ANNEX

THE DRAFT FREEDOM OF INFORMATION BILL AND ITS COMPATIBILITY WITH DIRECTIVE 90/313/EEC ON THE FREEDOM OF ACCESS TO INFORMATION ON THE ENVIRONMENT AND WITH THE AARHUS CONVENTION

FRIENDS OF THE EARTH

MAIN PROVISIONS REQUIRING AMENDMENT—A PRELIMINARY ANALYSIS

    "It is intended to revoke the current environmental information regime as set out in the Environmental Information Regulations 1998 (sic), and replace it with the FOI access right. The general access right will be modified in respect of environmental information where necessary to give the effect to the provisions of EC Directive 90/3013/EC (sic) and the Aarhus Convention (the United Nations Economic Commission for Europe (UNECE) Convention on access to information, public participation in decision making and access to justice in environmental matters, which the UK signed in June 1998). This will involve a detailed analysis of the two regimes—it is intended that the revised regime will be set out in the Bill when it is introduced into Parliament."

The Consultation Document (Cm 4355), May 1999, paragraph 54.

June 1999

 Main Provisions of the draft Freedom of Information Bill which require amendment to comply with Directive 90/313/EEC and/or the Aarhus Convention on Citizens' Environmental Rights

TIME LIMITS



Draft BillDirective 90/313 (and EIR[151]) Aarhus Convention (AC)Necessary amendment(s)

(a)   Primary obligation

"Any person is entitled . . . to have th[e] information communicated to him . . . promptly" (Cls 8(1) & 10(1))
Must "respond . . . as soon as possible". (Art 3.4) Must "ma[k]e available as soon as possible" (Art 4.2) Delete "promptly" and replace with "as soon as possible".
(b)   Back-stop

"in any event . . .
[within] . . . forty days . . . except where the authority has given a fees notice to the applicant . . . the period . . . is extended by the time taken to pay" (Cl 10(1))
"and at the latest within two months" (Art 3.4) "at the latest within one month . . . unless the volume and the complexity of the information justify an extension of this period up to two months after the request. The applicant shall be informed of any extension and of the reasons justifying if."
(Art 4.2)
Amend back-stop to comply with AC. Delete extension linked to fees notice.



EXEMPTIONS

1.   Information intended for future publication

Draft BillDirective 90/313 (and EIR[152]) Aarhus Convention (AC)Necessary amendments

"Information is exempt if . . . held . . . with a view to its publication
. . . at some future date (whether determined or not), and . . . it is reasonable in all the circumstances that the information should be withheld from disclosure until that date." (Cl 17(1))
No comparable provision. Discretionary refusal where disclosure "would involve the supply of unfinished documents" (Art 3.3) (Cf EIR: discretionary refusal if the information is "contained in a document or other record which is still in the course of completion" (Reg 4(2)(d))) No comparable provision. Discretionary refusal where the "request concerns material in the course of completion" (Art 4.3(c)) Delete. No "news management exemption" is allowed. See Ilisu Dam example.
2.   Information re security matters

3.   Information re national security


Draft Bill
Directive 90/313 (and EIR[153]) Aarhus Convention (AC)Necessary amendments

"Information is exempt . . . if it was directly or indirectly supplied . . . by, or relates to the work of [specified security bodies]" (Cl 18)
"Information which does not fall within section 18(1) is exempt . . . if exemption. . . is required for the purpose of safeguarding national security." (Cl 19)
Discretionary refusal "where it affects . . . national defence [or] public security" (Art 3.2). (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect. . . national defence or public security" (Reg 4(2)(c))) Discretionary refusal "if the disclosure would adversely affect . . . national defence or public security . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4(b)) Amend both exemptions to comply with AC. Must require adverse effect, and a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.


4.   Defence


Draft Bill
Directive 90/313 (and EIR[154]) Aarhus Convention (AC)Necessary amendments

"Information is exempt . . . if its disclosure . . . would, or would be likely to, prejudice [defence or the armed forces]"
(Cl 21)
Discretionary refusal "where it affects . . . national defence [or] public security" (Art 3.2) (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect . . .
national defence or public security" (Reg 4(2)(a)))
Discretionary refusal "if the disclosure would adversely affect . . . national defence or public security . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4(b)) Amend to comply with AC. Must require adverse effect, and a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
5.   International relations

Draft Bill
Directive 90/313 (and EIR[155]) Aarhus Convention (AC)Necessary amendments
"Information is exempt . . . if its disclosure . . . would, or would be likely to, prejudice (a) relations between the United Kingdom and any other State, (b) relations between the United Kingdom and any international organisation, (c) the interests of the United Kingdom abroad, or (d) the promotion or protection by the United Kingdom of its interests abroad." (Cl 22(1))
"Information is also exempt . . . if it is confidential information obtained from a State other than the United Kingdom or from an international organisation" (Cl 22(2))
Discretionary refusal "where it affects . . . international relations" (Art 3.2). (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect international relations" (Reg 4(2)(a))) Discretionary refusal "if the disclosure would adversely affect . . . [i]nternational relations . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4(b)) Amend to comply with AC. Delete cl 22(1)(c) and (d), as covering "international interests", not "international relations". Must require adverse effect, and a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
6.   Relations within the UK

Draft Bill
Directive 90/313 (and EIR[156]) Aarhus Convention (AC)Necessary amendments

"Information is exempt . . . if its disclosure would, or would be likely to, prejudice, relations between any [specified national] administration in the UK and any other such administration" (Cl 23)
Discretionary refusal "where it affects . . . the confidentiality of the proceedings of public authorities" (Art 3.2) (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect . . . the confidentiality of the deliberations of any relevant person" (Reg 4(2)(c)))

Discretionary refusal "where it would involve the supply of . . . internal communications." (Art 3.3). (Cf. EIR, discretionary refusal if "it is information the disclosure of which . . . would involve the supply of . . . any internal communication of a relevant person" (Reg 4(2)(d)))
Discretionary refusal "if the disclosure would adversely affect . . . [t]he confidentiality of the proceedings of public authorities, where such confidentiality is provided for under national law" . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4(b))

Discretionary refusal if the "request concerns . . .
internal communications of public authorities where such an exemption is provided for in national law or customary practice, taking into account the public interest served by disclosure." (Art 3(c))
Amend to comply with AC. Must require adverse effect, a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
7.   The Economy

Draft Bill
Directive 90/313 (and EIR[157]) Aarhus Convention (AC)Necessary amendments

"Information is exempt . . . if its disclosure . . . would, or would be likely to, prejudice [the economy] (Cl 24(1))
No comparable provision.No comparable provision. Environmental information defined as including "cost-benefit and other economic analyses and assumptions used in environmental decision-making" (Art 2(3)(c)) Delete.
8.   Investigations and proceedings conducted by public authorities


Draft Bill
Directive 90/313 (and EIR[158]) Aarhus Convention (AC)Necessary amendments

(a)   Criminal investigations and proceedings

"Information . . . is exempt . . . if it [(1)] has at any time been held . . . for the purposes of (a) any investigation which the public authority has a duty to conduct with a view to it being ascertained—

(i)  whether a person should be charged with an offence, or

(ii)  whether a person charged with an offence is guilty of it,

(b)  any investigation conducted by the authority with a view to determining whether the authority should institute criminal proceedings . . . , or

(c)  any criminal proceedings which the authority has power to conduct [; or, (2)] was obtained or recorded by the authority for the purposes of its functions relating
to [such] investigations . . . or criminal proceedings which the authority has power to conduct . . .
and . . . it relates to the obtaining of information from confidential sources." (Cl 25(1) & (3))
Discretionary refusal "where it affects . . . matters which are, or have been, sub judice, or under enquiry (including disciplinary enquiries), or which are the subject of preliminary investigation proceedings"
(Art 3.2)

(Cf. EIR: discretionary refusal if "it is information the disclosure of which . . . would affect matters which are, or have been, an issue in any legal proceedings or in any enquiry (including any disciplinary enquiry), or are the subject-matter of any investigation undertaken with a view to any such proceedings or enquiry" (Reg 4(2)(b)))
Discretionary refusal "if the disclosure would adversely affect . . . [t]he course of justice, the ability of a person to have a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(c)) Amend to comply with AC. Must require adverse effect, and a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
Draft BillDirective 90/313 (and EIR[159]) Aarhus Convention (AC)Necessary amendments

(b)   Other investigations
"Information . . . is exempt . . . if it [1] has been held . . . for the purposes of (a) any [other] investigation . . . conducted by or on behalf of the authority . . . for the purpose of [i] ascertaining whether any person has failed to comply with the law, or is responsible for any other improper conduct, (ii) . . . ascertaining a person's fitness or competence in relation to the management of bodies corporate or . . . any profession or other activity . . . (iii) . . . ascertaining the cause of an accident, [(iv)-(vi)] . . . protecting charities [in various ways], (vii) . . . securing the health, safety and welfare of persons at work, or (viii) . . . protecting persons other than persons at work against risk to health or safety . . . in connection with the actions of persons at work [; or 2] was obtained or recorded by the authority for the purposes of its functions relating to [such] investigations . . . and . . . it relates to the obtaining of information from confidential sources." (Cl 25(2) & (3))
Discretionary refusal "where it affects . . . matters which are, or have been, sub judice, or under enquiry (including disciplinary enquiries), or which are the subject of preliminary investigation proceedings" (Art 3.2). (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect matters which are, or have been, an issue in any legal proceedings or in any enquiry (including any disciplinary enquiry), or are the subject-matter of any investigation undertaken with a view to any such proceedings or enquiry" (Reg 4(2)(b))) Discretionary refusal "if the disclosure would adversely affect . . . [t]he course of justice, the ability of a person to have a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(c)) Amend to comply with AC. Must require adverse effect, and only on the course of justice, fair trial or a criminal or disciplinary inquiry. In addition there must be a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
Draft BillDirective 90/313 (and EIR[160]) Aarhus Convention (AC)Necessary amendments

(c)   Civil proceedings

"Information . . . is exempt . . . if it [1] has at any time been held . . . for the purposes of . . . any civil proceedings which are brought by or on behalf of the authority and arise out [an] investigation [under Clause 25(2), or [2]] was obtained or recorded by the authority for the purposes of its functions relating to . . . [such] proceedings . . . and it relates to the obtaining of information from confidential sources." (Cl 25(2) & (3))
Discretionary refusal "where it affects . . . matters which are, or have been, sub judice, or under enquiry (including disciplinary enquiries), or which are the subject of preliminary investigation proceedings" (Art 3.2) (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect matters which are, or have been, an issue in any legal proceedings or in any enquiry (including any disciplinary enquiry), or are the subject-matter of any investigation undertaken with a view to any such proceedings or enquiry" (Reg 4(2)(b))) Discretionary refusal "if the disclosure would adversely affect . . . [t]he course of justice, the ability of a person to have a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(c)) Delete
9.   Law enforcement

Draft Bill
Directive 90/313 (and EIR[161]) Aarhus Convention (AC)Necessary amendments

"Information which is not exempt information by virtue of section 25 is exempt . . . if its disclosure . . . would, or would be likely to, prejudice (a) the prevention or detection of crime, (b) the apprehension or prosecution of offenders, (c) the administration of justice, (d) the assessment or collection of any tax[es] . . , (e) the operation of the immigration controls, (f) the maintenance of good order in prisons [etc] . . , (g) the exercise by any public authority of its functions [relating to s 25(2)(a) investigations]" (Cl 26)
Discretionary refusal "where it affects . . . matters which are, or have been, sub judice, or under enquiry (including disciplinary enquiries), or which are the subject of preliminary investigation proceedings" (Art 3.2). (Cf. EIR: discretionary refusal if "it is information the disclosure of which . . . would affect matters which are, or have been, an issue in any legal proceedings or in any enquiry (including any disciplinary enquiry), or are the subject-matter of any investigation undertaken with a view to any such proceedings or enquiry" (Reg 4(2)(b))) Discretionary refusal "if the disclosure would adversely affect . . . [t]he course of justice, the ability of a person to have a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(c)) Amend to comply with AC. Must require adverse effect, and only on the course of justice, fair trial or a criminal or disciplinary inquiry. In addition there must be a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions. Delete tax, immigration, prisons and s 25(2)(a) investigations' exemptions.
10.   Court records etc


Draft Bill
Directive 90/313 (and EIR[162]) Aarhus Convention (AC)Necessary amendments

"Information . . . is exempt . . . if it is held only by virtue of being contained in [documents filed, served or created in court or tribunal proceedings]" (Cl 27(1))
Discretionary refusal "where it affects . . . matters which are, or have been, sub judice, or under enquiry (including disciplinary enquiries), or which are the subject of preliminary investigation proceedings" (Art 3.2). Public authorities defined as excluding "bodies acting in a judicial or legislative capacity" (Art 2(b)) (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect matters which are, or have been, an issue in any legal proceedings or in any enquiry (including any disciplinary enquiry), or are the subject-matter of any investigation undertaken with a view to any such proceedings or enquiry" (Reg 4(2)(b)). Information excluded if "held . . . for the purposes of any purposes of any judicial or legislative functions" (Reg 2(1)(b))) Discretionary refusal "if the disclosure would adversely affect . . . [t]he course of justice, the ability of a person to have a fair trial or the ability of a public authority to conduct an enquiry of a criminal or disciplinary nature . . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(c)). Public authorities defined as excluding "bodies or institutions acting in a judicial or legislative capacity" (Art 2). Amend to comply with AC. Directive and AC exempt bodies, not information (eg, if held by another body); and arguably only when acting in a judicial or legislative capacity. Blanket exemption not permitted. Must require adverse effect, and only on the course of justice, fair trial or a criminal or disciplinary inquiry. In addition there must be a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions.
11.   Decision-making, policy formulation and the effective conduct of public affairs


Draft Bill
Directive 90/313 (and EIR[163]) Aarhus Convention (AC)Necessary amendments

"Information held by a government department is exempt . . . if it relates to (a) the formulation or development of government policy, (b) communications between Ministers . . , (c) . . . advice by any of the Law Officers . . , (d) the operation of any Ministerial private office." (Cl 28(1))
"Information . . . held by a government department [but not exempt under Cl 28(1)] and . . . information . . . held by any other public authority . . . is exempt . . . if, in the reasonable opinion of a qualified person, disclosure . . . (a) would, or would be likely to, prejudice the maintenance of . . . collective responsibility of Ministers . . . , (b) would, or would be likely to, inhibit . . . the free and frank provision of advice, or . . . exchange of views for the purposes of deliberation, or (c) would otherwise prejudice, or would be likely to prejudice, the effective conduct of public affairs." (Cl 28(2) & (3))
Discretionary refusal "where it affects . . . the confidentiality of the proceedings of public authorities" (Art 3.2). (Cf EIR: discretionary refusal if "it is information the disclosure of which . . . would affect . . . the confidentiality of the deliberations of any relevant person" (Reg 4(2)(c))
Discretionary refusal "where it would involve the supply of . . . internal communications." (Art 3.3). (Cf EIR, discretionary refusal if "it is information the disclosure of which . . . would involve the supply of . . . any internal communication of a relevant person" (Reg 4(2)(d))
Discretionary refusal "if the disclosure would adversely affect . . . [t]he confidentiality of the proceedings of public authorities, where such confidentiality is provided for under national law"
. . . [This ground] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4(b))
Discretionary refusal if the "request concerns . . . internal communications of public authorities where such an exemption is provided for in national law or customary practice, taking into account the public interest served by disclosure." (Art 3(c))
Amend to comply with AC. * No blanket or two-tiered exemption permitted;

* Must require adverse effect, a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions;
* Delete "the operation of any Ministerial private office.";
* Qualify exemption by excluding from its scope the views of nature conservation agencies in decision-making processes, as the European Court of Justice has held that these are covered by 90/313 (Mecklenburg v Kreis Pinneberg-Der Landrat (Case C-321/96, 17 June 1998)).
12.   Commercial interests


Draft Bill
Directive 90/313 (and EIR[164]) Aarhus Convention (AC)Necessary amendments

"Information is exempt . . . if it constitutes a trade secret [or] if its disclosure . . . would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)" (Cl 34)
Discretionary refusal "where it affects . . . commercial and industrial confidentiality, including intellectual property" (Art 3.2) (Cf EIR: Discretionary refusal if "it is information the disclosure of which . . . would affect the confidentiality of matters to which any commercial or industrial confidentiality attaches, including intellectual property." (Reg. 4(2)(e)) Discretionary refusal "if the disclosure would adversely affect . . . [1] [t]he confidentiality of commercial and industrial information, where such confidentiality is protected by law in order to protect a legitimate economic interest. Within this framework, information on emissions which is relevant for the protection of the environment shall be disclosed . . . [or 2] [i]ntellectual property rights . . . [These grounds] for refusal shall be interpreted in a restrictive way, taking into account the public interest served by disclosure and taking into account whether the information requested relates to emissions into the environment." (Art 4.4(d) & (e)) (Art ) Amend to comply with AC. "Commercial interests" too wide; must have legitimate and legal protection in respect of the information before it can be exempted; and environmental emissions cannot be exempted (unless subject to that legitimate legal protection). In any event, must require adverse effect, and a restrictive interpretation, taking into account public interest in disclosure and whether information relates to environmental emissions. The draft Bill is also wider than the test for withholding information from public pollution registers etc: "if its being contained in the register would prejudice to an unreasonable degree the commercial interests of [a specific] individual or person" (eg, Environmental Protection Act 1990, ss 22(11) & 66(11))
13.   Power to confer additional exemptions

Draft Bill
Directive 90/313 (and EIR[165]) Aarhus Convention (AC)Necessary amendments

The Secretary of State can create additional exemptions by order, with retrospective effect, if "it appears to him that the public interest in conferring the additional exemption outweighs the public interest in allowing public access to the information" (Cl 36)
No comparable provision.No comparable provision. Delete retrospective effect. Limit the exercise of the general power to a duty not to create an exemption that is not provided for in AC or under EU law.
14.   Effects of disclosure

Draft Bill
Directive 90/313 (and EIR[166]) Aarhus Convention (AC)Necessary amendments

"Where (a) the disclosure under this Act of any information . . . would neither have, nor be likely to have, a particular effect [as] mentioned . . , but (b) would, or would be likely to, have that effect if any other information (whether or not held by the public authority and whether or not accessible, or likely to become accessible, to members of the public) became available at the same time or subsequently, the disclosure of the information requested shall be taken . . . to have that effect." (Cl 37)
No comparable provision.No comparable provision. Delete.
15.   Duty of separation and partial supply


Draft Bill
Directive 90/313 (and EIR[167]) Aarhus Convention (AC)Necessary amendments

No express duty of separation and partial supply.
"Information shall be supplied in part where it is possible to separate out [exempt] information . . . " (Art 3.2) (Cf EIR: Must supply "information contained in the same record as, or otherwise held with, other information which is [exempt] . . . unless it is incapable of being separated from the other information . . . " (Reg 4(4))) "Each Party shall ensure that, if information exempted from disclosure . . . can be separated out without prejudice to the confidentiality of the information exempted, public authorities make available the remainder of the environmental information that has been requested." (Art 4.6) Insert an express duty to separate out and supply non-exempt information.
COSTS

Draft Bill
Directive 90/313 (and EIR[168]) Aarhus Convention (AC)Necessary amendments

(a)   Fees notices

"A public authority . . . may . . . give the applicant a . . . fees notice . . . stating that a fee of an amount specified in the notice is to be charged" (Cl 9(1))
"Where a fees notice has been given . . . the public authority is not obliged to comply with [the request] unless the fee is paid . . . " (Cl 9(2))
"Any fee . . . must be determined . . . in accordance with regulations made by the Secretary of State." (Cl 9(3))
"The Member States may make a charge for supplying the information, but such charge may not exceed a reasonable cost" (Art 5)
(Cf EIR: may impose a "charge on any person in respect of the costs reasonably attributable to the supply of the information . . . [and] . . . the supply of any information . . . [may be made] conditional on the payment of such a charge." (Reg 3(4)(b)))
"Each Party may allow its public authorities to make a charge for supplying information, but such charge shall not exceed a reasonable amount. Public authorities intending to make such a charge . . . shall make available . . . a schedule of charges . . . indicating when the supply of information is conditional on the advance payment of such a charge." (Art 5.8) No extension of the time limit is permitted under 90/313 or AC.
90/313 contains no "pre-payment" provision. "Reasonable" cost cap must be inserted in the legislation (including in cl 16), not left to the Secretary of State's unrestricted discretion. Charging for officials' time may be unlawful: "While [Art 5] does not expressly preclude . . . levying a charge for the time and effort of public officials, such an approach seems . . . fundamentally incompatible with the principal features of the Directive . . . Since access to environmental information is in the public interest, it follows that the public authorities, and, ultimately, the general public through the State budget, should bear that part of the burden making this information available which is represented by the time and effort of public officials."
(A G Fennelly, in Commission v Germany (217/97), January 1999).
Draft BillDirective 90/313 (and EIR[169]) Aarhus Convention (AC)Necessary amendments

(b)   Cost exceeding prescribed limit

No obligation to comply with request "if the authority estimates that the cost of complying with the request would exceed the [prescribed] appropriate limit"
(Cl 12(1))
No comparable provision.No comparable provision. Delete.







151    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

152    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

153    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

154    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

155    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

156    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

157    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

158    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

159    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

160    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

161    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

162    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

163    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

164    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

165    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

166    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

167    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

168    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back

169    The Environmental Information Regulations 1992, as amended by The Environmental Information (Amendment) Regulations 1998. Referred to in italics where different from Directive 90/313/EEC on the freedom of access to information on the environment. Back


 
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