False economies?
I've mentioned already (here and here) some of the surprising contents of the Frontier Economics report on the cost of FOI, but there are also some striking omissions.
From what I can see, the report does not even explicitly state the projected savings from the government's actual set of proposals.
The report states (Table 3) that the proposal to take into account reading/consideration/consultation time would save £8.2 million. But the additional saving from then also aggregating non-similar requests is not explicitly stated. However, extrapolating from the figures in Tables 1 and 2 suggests that it is nearly £1 million.
Apart from the fact that these figures are based on various arbitrary assumptions, as discussed, the report then fails to set against this various factors which could considerably reduce these projected savings:
* the scope for an increase in the number of internal reviews from frustrated requesters;
* the numerous ways in which requesters could (and doubtless would) seek to evade the aggregation policy;
* the cost of policing and attempting to enforce the aggregation proposal.
Nor does the report consider the possibility that extra scrutiny of public spending through FOI can result in big savings of public money.
Finally, there are all sorts of ways in which the costs of FOI could be reduced which are not touched on at all - for example, improving the quality of initial responses to information requests, so that unnecessary and expensive internal reviews are avoided.
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