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Defence FOI 405/25/26
FOI Applicant ‘J’
Via email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear J,
Notification of a request consultation process – FOI 405/25/26
I refer to your request for access to the following documents, in the possession of the Department of
Defence (Defence) under the
Freedom of Information Act 1982 (Cth) (FOI Act).
I am an officer authorised under section 23(1) of the FOI Act to make decisions in relation to FOI
requests.
I am writing to tell you that I believe that the work involved in processing your request in its current
form would substantial y and unreasonably divert the resources of this agency from its other
operations due to its size and scope. This is called a ‘practical refusal reason’ (section 24AA).
On this basis, I intend to refuse your request. However, before I make a final decision to do this, you
have an opportunity to revise your request. This is cal ed a ‘request consultation process’ as set out
under section 24AB of the FOI Act. You have
14 days to respond to this notice in one of the ways set
out below.
Reason for Intending to Refuse Your Request
In your request, you sought the following documents:
Contractual Arrangements
The current head contract (and any variations or schedules) between the Department of
Defence and Tol Transitions Pty Ltd for the provision of Defence member relocation and
removal services.
In particular, I seek any schedules, annexures, or statements of work that set out:
Service standards or key performance indicators (KPIs),
Complaints-handling and dispute-resolution obligations, and
Responsibilities of Tol in relation to subcontracted removalists.
Performance and Compliance
The most recent 12 months of:
Departmental audits, reviews, or performance reports assessing Tol ’s compliance with the
above service standards,
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Any summary reports provided by Tol to Defence under contractual reporting obligations.
Scope and exclusions:
I do not seek access to personal information of Defence members or private individuals.
I do not seek routine correspondence or duplicate copies of the same document.
I accept that commercially sensitive financial details (such as unit pricing) may be redacted
under s 47 of the Act, provided the remainder of the contract and KPIs are released.
I am an ADF member directly affected by the operation of this contract and seek these
documents to better understand the contractual standards and oversight mechanisms in place.
For the purpose of providing this notice, I have considered whether processing your request would
be unreasonable. I consider that processing your request, as it currently stands, would be
unreasonable because the work involved in processing your request in its current form would
substantially and unreasonably divert the resources of the agency from its other operations.
Section 24(1) of the FOI Act provides that an agency may refuse to give access to documents in
accordance with an FOI request if:
• a practical refusal reason exists in relation to the request; and
• following a request consultation process under section 24AB of the FOI Act, the agency is
satisfied that the practical refusal reason still exists.
Section 24AA(1)(a)(i) of the FOI Act provides that a practical refusal reason exists in relation to an FOI
request if the work involved in processing the request would substantial y and unreasonably divert
the resources of the department from its other operations.
I find that a significant amount of resources would have to be diverted to arrange for the required
searches to be undertaken by various areas of Defence, to then review documents that were
identified as being possibly relevant to your request, and finally, to undertake the decision making
process on any documents that did meet the parameters of your request.
Preliminary searches have identified 108 documents comprising of more than 800 pages currently
falling within the scope of the request. At a conservative average of 2 minute per page, to review
each page of the material would take an officer in excess of 26 hours, or nearly 3.5 days to conduct
this initial step. This time does not take into account any redactions that may be required to each
page or consultations that are required to take place prior to release. As such, I regard the actual
time required to fulfil this request to be considerably higher than this estimate and am satisfied that
your request as it is currently framed, constitutes valid practical refusal grounds.
Request Consultation Process
You now have an opportunity to revise your request to enable Defence to process it.
Revising your request can mean narrowing the scope of the request to make it more manageable or
explaining in more detail the documents you wish to access. For example, by providing more specific
information about exactly what documents you are interested in, including a timeframe to enable
accurate documents searches, Defence wil be able to pinpoint the documents more quickly, and
avoid using excessive resources to process documents you are not interested in.
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Before the end of the consultation period, you must do one of the following, in writing:
• Withdraw your request
• Make a revised request
• Tell us that you do not wish to revise your request.
The consultation period starts on the day after you receive this notice and ends on
13 October 2025.
If you revise your request in a way that adequately addresses the practical refusal reason outlined
above, we wil recommence processing it. (Please note that the time taken to consult you regarding
the scope of your request is not taken into account for the purposes of the 30 day time limit for
processing your request.)
In your consideration of submitting a revised request, you may like to consider:
• limiting your request to seek access to a specific part/s of the contract;
• limiting your request to be for one type of document; and
• providing a shorter timeframe for documents.
If you do not do one of the three things listed above during the consultation period your request wil
be taken to have been withdrawn.
Contact Officer
If you would like to revise your request or have any questions, please contact the Case Manager by
email, xxx.xxxxxxxxxxxxxx@xxxxxxx.xxx.xx.
Yours sincerely,
Elise Wattam
Department of Defence
Campbell Offices
Canberra BC ACT 2610
29 September 2025
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