Call for proposals – Environmental Information Regulations: How are they working in practice at the local level?

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In one sentence

mySociety is looking for an individual, organisation or joint team to explore requests made through WhatDoTheyKnow.com to understand how requests for environmental information are being used in practice, highlighting success stories in releasing information at the local level, problems requesters encountered, and suggestions on how mySociety could better make use of the environmental information requests. 

About mySociety

mySociety is the charity behind UK civic services like TheyWorkForYou, WhatDoTheyKnow, FixMyStreet, and WriteToThem. We build open, digital solutions to help repower democracy, in the UK and around the world.

mySociety’s climate programme is funded by Quadrature Climate Foundation and the National Lottery Community Fund.

About mySociety’s existing work in this area 

mySociety’s Climate Programme is exploring how digital tools and approaches can work to reduce the third of UK emissions that local authorities have influence over. A key focus of this work is improving the quality and quantity of information that exists around local climate action. We make local authority plans more accessible and visible, campaign for better official data, and support pooling and crowdsourcing of data to improve knowledge and accountability for climate action. You can read more about mySociety’s Climate programme here.

WhatDoTheyKnow.com is a website built by mySociety, and administered by mySociety in partnership with volunteers, that helps people make Freedom of Information (FOI) requests and publishes the results in public. Over 900,000 FOI requests have been made through this platform. We have published research looking at the scale of FOI in local government, and in improving FOI through the UK, and Europe

About this project

Our ultimate goal in our climate work is to decrease UK carbon emissions that are either directly controlled or influenced by UK local government. Our main approach is by improving the information environment so that a variety of local institutions and actors are better able to understand the current situation, share knowledge on their approaches, and take more informed action. We have done this by making local authorities own plans and documents more discoverable and searchable, supporting crowdsourcing of information about plans and actions, pooling information held by different groups of campaigners, and arguing for improved publishing of official information

Another method open to us is to use (or facilitate the use of) Freedom of Information laws to get more official data and information into the public domain. Freedom of Information laws give a wide range of public access to information held by authorities. This is useful in releasing information about authorities’ own plans and actions, but is also useful in releasing underlying information which local authorities, so that other organisations (including companies, charities, and other public sector bodies) can use to inform their own approach and actions. 

The Environmental Information Regulations (EIR) substantially overlap with Freedom of Information. EIR requests make it easier to ask for and receive information specifically related to the environment, and covers a wider range of organisations than the general Freedom of Information law. We believe there is the potential to use improved support and guidance for Environmental Information Requests to facilitate more information relevant to local climate action being released, and being made discoverable by local authority actors, civil society and communities. This might take the form of modifications to WhatDoTheyKnow, or light-weight specialist services that sit on top of WhatDoTheyKnow’s FOI archive and infrastructure (similar to FragDenStaat’s Climate Helpdesk). 

But before we can do that, we want to understand more about Environmental Information Requests. WhatDoTheyKnow’s archive gives us access to a huge number of requests made for environmental information, but we understand very little about the contents of these requests. 

Based on a quick text search, we have a maximum of 70,000 requests that in some way mention environmental information regulations. As part of our wider pool of 1 million FOI requests, there may be other requests with environmental interests that have not explicitly mentioned EIR. We are looking for a contractor to explore the large WhatDoTheyKnow dataset, and highlight themes, patterns, and individual examples that show how EIRs are being used, obstacles users are encountering, and the implications of this for mySociety’s future work in this area. 

The available budget for this work is up to £8000-10,000 (inclusive of VAT), and the project would need to be completed by the end of July. There is a small amount of flexibility on this end date – but we are looking to make decisions in August about best ways to follow up the project in September. 

What we want to know more about

The broad goal of this project is to refine our understanding of how EIR works in practice. We’ve broken this into six areas we’d like to understand more about. 

  1. EIRs have fewer exemptions, and a higher threshold for withholding material on public interest grounds, than FOI and. In principle, relevant information should be easier to get through EIR, but it is unclear how much this is significant in practice. We want to know more about the kinds of information that are successfully being released through EIR.
  2. EIRs apply to more types of organisation – and organisations that have an important local footprint may be accessible to FOI. We want to know about the kinds of institutions and authorities who are or could be releasing information under EIR that is relevant to our local emissions goals.
  3. Authorities should consider which regime a request falls under – and default to the more permissive EIR regime when a request is for environmental information. We want to know if there are cases where information is being withheld under FOI but should have been considered under EIR.
  4. EIR might be more poorly understood by both requesters and authorities – information may be being incorrectly withheld that should be released. We want to understand any patterns of refusal that would inform advice tools. 
  5. At the moment we don’t have an automatic way of identifying EIR responses (when authorities have judged a request under these rules), but it should be possible to create classification rules that separate them from FOI requests. We want to refine this approach so we can more consistently identify and analyse EIR responses, so they can be in current or future local climate services.
  6. The big way in which EIRs are less accessible is that authorities can charge fees without a minimum amount of time taken, which is the case for FOI requests. Generally we think this doesn’t happen much (the ICO’s guidance is not to charge for a reasonable request), but we don’t know. We want a clearer sense of how often authorities ask that requesters pay a fee for environmental information.

What we are looking for in and from a partner

Expertise / skill set

We think there are a few different approaches to this project and are open to a range of approaches. In general we anticipate two main kinds of applicants: one leaning more on technical ability, and the other on specialist knowledge of FOI and EIR, or environmental data more broadly. For either kind of applicant, we can provide basic support in the other skillset. The ideal candidate would cover all of these bases (where a subject matter expert makes the technical search process sharper) – and we can help facilitate partnership applications between technical and specialist partners who might otherwise submit separately. If you are interested in this route, please fill out this collaboration form and we can help put you in contact. 

The key thing an applicant needs to have is an approach to searching the large quantity of information on WhatDoTheyKnow. At a minimum this requires some technical skills and ability to navigate the site – but beyond that might be accomplished by large scale text analysis, or a sampling and search method. WhatDoTheyKnow’s search allows searching for specific search terms – but the search count is not always accurate for larger queries. 

For technical strategies, we can provide data exports to enable searches off-platform. But for subject matter experts, we can also provide an Excel sheet of links to URLs that have triggered particular keywords, and authorities. 

Something that is important to us is being able to point to individual examples – and so approaches based on aggregate analysis (which might be the better approach to identify the scale of fees being charged, for instance, or automatically analyse themes of requests) need to also be able to drill down to individual requests. 

With this in mind, the following is a list of skills we would expect the candidate to have a couple but not necessarily all of the following:

  • Technical skills
    • Experience with search and processing large amounts of text delivered in a mostly unstructured way.
    • Experience with Natural Language Processing (NLP) or automated topic extraction. 
  • Subject matter skills
    • Knowledge and experience of Freedom of Information and/or Environmental Information Requests
      • Especially practical understanding of refusal and appeal grounds in both FOI and EIR.
    • Less important, but understanding of the wider European context of Environmental Information Regulations might provide additional understanding of potential approaches mySociety could take in the UK. 

Alignment with values and aims

Our Repowering Democracy strategy puts a special emphasis on embedding equity and inclusion in our work practices and services, and our work aims in general to fulfil values of equity/justice, openness and collaboration

Applicants should consider if this presents any obstacles to a working relationship, and think about how these values should be reflected in the project plan, either in terms of subject matter to investigate, or research approach.

Working practices

mySociety works flexibly and remotely, and there is no requirement to work from or visit an office. Applicants can distribute their work as appropriate over the time available, but we would expect regular check-ins on progress to be arranged over that period. A shared Slack channel and a specific contact person will be used to help coordinate and quickly share questions and information between mySociety and the researcher. 

Successful applicants would be expected to abide by the mySociety Code of Conduct in mySociety communications channels and events. 

Outputs and deliverables

The purpose of this project is to inform mySociety’s future projects, especially forming the base of knowledge around the use of EIRs for a prototyping week.

We are open to the form of outputs – this may take the form of one large report, briefings around our individual question areas, proposed amendments to guidance, etc. For technical submissions, analysis code under an appropriate licence would form part of the output.

The outputs should also work as a general contribution to knowledge of the current use of EIRs, and we might either publish or edit down and publish these briefings/reports.

Q&A and contact details

The application timeline includes a Q&A event, to which you can sign up at the link at the top of this document. The Q&A session will include an element to help individual researchers coordinate to form a joint submission (applications are also welcome from individual researchers). Answers will be made available in a video on this page for applicants who cannot take part. Questions can be emailed to the contact address below. 

Please send any queries or questions to research-commissioning+eir2023@mysociety.org and mention which project it is in regard to. Questions in advance are preferred and will be prioritised in the session. 

Your application

Applications can be submitted by individuals, organisations, or joint teams of individuals/organisations. These should be sent to research-commissioning+eir2023@mysociety.org by the closing date. 

You should submit a short application, of up to 4 pages of A4. A template for the response can be downloaded at the link at the top of this page, and covers: 

  • Who you are (whether an individual, organisation, or joint team).
  • A description of your previous experience/previous work and why you want to take on this project.
    • To the extent that this is possible, this should be anonymous and not include names of the org or members of the team (to help with anonymous stages of the recruitment process)
  • How you would approach and deliver this project – a short project plan with approximate timings. 
    • This could include discussion of appropriate outputs for the project, and balancing technical and subject matter requirements. 
  • The total value (£) of your proposal (including VAT), and high-level breakdown of costs (perhaps an indication of days per person, any other expenses). This does not need to include production costs of the report. 
    • Given the cost of the project, we will not be giving a great deal of weight to budget plans so please keep this short and high-level – we can dig into further details during interviews, if necessary.
  • A short description of the individuals or team who will do the work, including biographies

There is a separate equalities monitoring form to fill out, which is processed separately from the main application (there is a link to the form in the application form). This is for understanding the reach of our method of distributing the call for proposals. 

If you are interested in joining a ‘researcher pool’ mailing list that we will contact with details of future projects, please see the link at the top of this document. 

Application timeline

If there are changes during this timeline, the table on the website version of this form will be updated. 

Stage Date Description
Call for proposals published 7 March 2023  
Q&A Webinar 21 March 2023 An open, online public event for interested bidders to learn more about the project and ask questions. This will be recorded and available afterwards. You can submit questions in advance to research-commissioning@mysociety.org. Questions in advance are preferred. 
Questions answered 23 March 2023 Video of the webinar to be made available to all potential bidders, in addition to answers to any other questions submitted via email
Deadline for applications 31 March 2023 (end of day)  
Initial decisions 7th April 2023 Applicants to be informed whether they have made it through to a short panel interview (and may be asked for a sample of existing work). Applicants not progressing past this stage to be offered written feedback
Interviews w/c 10 April 2023 Format to be decided, but this will likely be a one-hour panel interview with several people involved in the climate programme, towards the end of the week (14th, 15th April)
Final decision w/c 18 April 2023 Remaining applicants to be informed of the final decision. Applicants not progressing to be offered feedback
Project briefing/kick-off meeting End of w/c 18 April 2023 To include a brief introduction to mySociety, discussion of any onboarding required and approach to project management, communication and catch-ups
Project deadline End of July 2023 End of project
(Time range of project is a little flexible – we want it to inform decisions in August about any follow up work in September)

What happens after the project 

We intend to publish the report or briefs you produce, credited to you, on the mySociety website, licensed under a Creative Commons licence (see recent publications on research.mysociety.org for details). We may make some light edits (beyond proofreading) before we publish. You will be free to make publicly available your own version should you wish to, and any other material based on the research you conducted. 

We will convene a short ‘lessons learned’ session for the contractor and mySociety to discuss how the project went – what went well and anything that could have been improved. We will also discuss any future work based on the delivered project (e.g. if you are an academic and might want to co-author an article) and our ongoing relationship. We would also like to arrange a presentation on the project to mySociety staff, and there may also be an opportunity to promote the work in a public event held by mySociety (budgeting for this would be separate to the project above). 

Terms and conditions

Interested parties must be UK-based individuals or organisations.

 

Questions and Answers

 

For data analysis, what format is the data available in?

We create a regular research export of the database in CSV format. This doesn’t include the last few months of data and removes requester names where possible (this is generally available on the website, but we are trying to future proof against information being too available if redactions are needed in future).

There is a a data table of requests made by authority, and then a dataset of the individual messages (with full text) for each request. 

We currently don’t make the downloaded files themselves available in bulk (but are accessible through the site) – but the bulk export does include any cached conversion of a word document or pdf attached.

We can produce reduced data sets limited to specific authorities or keywords. For instance, to those flagged as potentially EIR projects at the start.

WhatDoTheyKnow data sharing policy for bulk data

What is the time scale for the research?

Broadly we’re looking for work to be completed by the End of July to help us inform how we spend our time in September. Depending on the nature of outputs, there may be some flexibility around this.

The retained EU law will ‘sunset’ EIR at the end of the year, unless explicitly retained. How does this work relate to that?

Our current default assumption is “everything will be fine” and this project can proceed as if EIR will continue past 2023. In the event it is looking like everything is not fine, this research helps us understand more about the impact of EIRs for campaigning purposes.

How have you handled projects like this before and how have they worked?

We’ve previously commissioned two pieces of research: one was about how we should commission research, the other was the role of local government in climate change. In both case we worked with a sole researcher, with regular check-in meetings and a shared slack channel. That said, we’re open to group applications (and this project may be appropriate for that). Neither of those projects was particularly data heavy, but we have worked to provide external researchers with data before. 

What support will you give the project?

The main support and contact for the project will be Alex Parsons (Senior researcher) from aa research and data perspective. There is limited available of the WhatDoTheyKnow on a day to day basis team – but I can either answer questions or get answers to questions we need to know.

If you have any other questions about this project or the application, please email : research-commissioning+eir2023@mysociety.org