Fallen Stock and AWPP

Summary

A request for communications regarding the Animal Waste Processing Plant and fallen stock held by the Attorney General's Chambers was refused because fulfilling it would require substantial compilation of information.

Key Facts

• The request was received on 2025-09-08 and the outcome was issued on 2025-09-22.
• The authority refused the request under section 11(3)(b) of the Freedom of Information Act 2015.
• The refusal was based on the requirement to undertake substantial compilation or collation of information under section 8(3)(c).
• The authority noted that most identified information would likely be legal advice subject to Legal Professional Privilege.
• The request covered a two-year timeframe from September 2023 to September 2025 involving multiple departments.

Data Disclosed

• 2025-09-08
• 2025-09-22
• 1st September 2023
• 5th September 2025
• section 11(3)(b)
• section 8(3)(c)
• section 40
• Animal By-Product Regulations 2019
• Collection and Disposal of Waste Regulations 2000

Exemptions Cited

• Section 11(3)(b) - Practical refusal reason (substantial compilation)
• Section 8(3)(c) - Not required to undertake substantial compilation
• Section 40 - Legal Professional Privilege

Original Request

Under the Freedom of Information Act 2015, I am requesting the following information held by The Attorney General's Chambers. Please provide all external and internal communications with the following titles and/or references within content of communication/documentation;- * 'Animal Waste Processing Plant' or AWPP or both * 'fallen stock, animal by-product (ABP) or both * Animal By-Product Regulations 2019, the Collection and Disposal of Waste Regulations 2000 or both, where it is used in reference to the Animal Waste Processing Plant (AWPP), fallen stock, animal by- product, or any of these references. Timeframe: from 1st September 2023 to 5th September 2025. For the timeframe above, please include; * Emails (including attachments), internal and external messages, memos/notes, briefing papers, meeting agendas/minutes/notes, decision logs, internal reports, and guidance circulated internally. * Internal Communications within the Attorney General's Chambers and between the Attorney General's Chambers and the Department of Infrastructure, and other Departments including, but not limited to Department of Environment Food & Agriculture, Cabinet Office, and any other Department where communications have referenced the above. Please include any reports or recommendations within documentation and communications. Please supply the information electronically. For emails, if possible, please provide with attachments. In order to reduce costs, you may exclude exact duplicates.

Data Tables (1)

Full Response Text

Attorney General's Chambers 2nd floor Belgravia House Circular Road, Douglas Isle of Man, IM1 1AE Telephone: (01624) 685452
E-mail: attgen@gov.im

Our ref: 4920773 18 September 2025

Dear ###

This request is being handled under the Freedom of Information Act 2015.

We write further to your request received 8 September 2025, which states:

"Under the Freedom of Information Act 2015, I am requesting the following information held by The Attorney General's Chambers.

Please provide all external and internal communications with the following titles and/or references within content of communication/documentation;-

• 'Animal Waste Processing Plant' or AWPP or both
• 'fallen stock, animal by-product (ABP) or both
• Animal By-Product Regulations 2019, the Collection and Disposal of Waste Regulations 2000 or both, where it is used in reference to the Animal Waste Processing Plant (AWPP), fallen stock, animal by-product, or any of these references. Timeframe: from 1st September 2023 to 5th September 2025.

For the timeframe above, please include;

• Emails (including attachments), internal and external messages, memos/notes, briefing papers, meeting agendas/minutes/notes, decision logs, internal reports, and guidance circulated internally.
• Internal Communications within the Attorney General's Chambers and between the Attorney General's Chambers and the Department of Infrastructure, and other Departments including, but not limited to Department of Environment Food & Agriculture, Cabinet Office, and any other Department where communications have referenced the above.

Please include any reports or recommendations within documentation and communications.

Please supply the information electronically. For emails, if possible, please provide with attachments.

In order to reduce costs, you may exclude exact duplicates."

While our aim is to provide information whenever possible, in this instance, a practical refusal reason has been applied under section 11(3)(b) of the Freedom of Information

Act 2015 (“the Act”), as complying with the request for information would require the public authority to do one or more of the matters mentioned in section 8(3) of the Act [things a public authority is not required to do by the Act], ie 8(3)(c) [undertake substantial compilation or collation of information that it holds].

In the interests of providing reasonable advice and assistance to you in respect of your request [s15 of the Act – Duty to provide advice and assistance], the request, as framed, is exceptionally broad. It covers a two-year period, multiple categories of communications [including emails, attachments, notes, briefings, agendas, and reports], and involves not only internal material, within the Attorney General’s Chambers, but also exchanges with several other Departments. Responding to this request would therefore require the review of a very wide range of records to identify [potentially] relevant information, followed by detailed consideration of each for duplication and exemption. As such, this would amount to a substantial exercise in compilation and collation that the Act does not require a public authority to undertake, hence the application of a practical refusal reason. In addition, the majority of information likely to be identified will be legal advice, and related documentation. Such material would likely be subject to the qualified exemption under s40 of the Act [Legal Professional Privilege), as a result, even if the searches were undertaken, little or no substantive information would likely be disclosed.

You may wish to consider directing a request to DEFA, or other Departments, which are more likely to hold factual or administrative material on this subject, however, before doing so, you may wish to consider refining your request by limiting the timeframe, restricting the scope to particular Departments, or focusing on specific information only. This would significantly reduce the burden of compilation and collation, and may improve the prospects of locating disclosable information.

Please quote the reference number 4920773 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.

In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.

David Kinrade Head of Crown