I refer to the paragraph sequence in the reply from CAA.

(b) The fact that something is 15 GB in size and is therefore substantial and complex, is not in itself a reason to rely on section 18(f) (that the information requested cannot be made available without substantial collation or research). While the CAA says it would require "substantial" CAA resources to extract the information, they provide no estimate of time. Furthermore, it is not clear that "collation" or "research" are the tasks that are implemented here. (However I could be wrong).

However, it is helpful that they have taken the initiative to explain the methodology for calculating the fees. This is a positive action by CAA to help the requester.

Before a request is refused under 18(f), the organisation needed to have considered whether consulting with you would have resulted in them not relying on the 18(f) administrative withholding reason. There is no evidence that they carried out that consideration.

(c) The first action that the organisation ought to have taken in respect of this part of your request was for it to have exercised its duty of assistance under para. 13(b), by contacting you to assist you in refining that part (c) of your request so that your request could be stated with due particularity.

In relying upon 18(f), they could also, in the same breath, exercised their obligation under 18B to consult with you before relying on para. 18(f) to refuse your request.

Furthermore, they also needed to consider making a charge under 18A, before relying on para. 18(f). (I would anticipate a high charge for them looking through myriad sources.)

The fact that your request is broad, does not necessarily result in it lacking due particularity (as required of requesters in ss. 12(2)).

Admittedly, making such broad requests is often not helpful to an organisation, as the ambit is so wide the task of trying to collate information held in various sources is overwhelming. Information these days, is easily created due to the ease with which it is generated by computers. It is better for the requester to word such requests in a way that focuses on what it is they want to know, rather than emphasis document types (minutes, etc). If you must ask for "all documentation" then some options are:

1. ask for a list of substantive (major) documents on the subject

2. contact the orgaisation and ask them to explain what other information they hold (in addition to what is on their website, which is the first place you should look).

I hope the above is helpful guidance to organisations and requesters.