been made may undermine the confidence of Ministers that advice has been prepared fully objectively to support their decisionmaking rather than with an eye to a wider audience. While recognising the general public interest in openness in Government, the Department considers it is in the public interest that the business case for the HMLC, that informs internal discussions, is kept confidential in order that Ministers and officials may conduct a full and frank discussion of the issues at hand, in the knowledge that their discussions will remain confidential during that period and will not be subject to premature disclosure. This relates to optimism bias particularly because as the project develops, more accurate costing of project or programme specific risk management can be undertaken. The optimism bias assessment relates specifically to the planned HMLC at this point in time, including the current market prices and delivery timeline. Releasing figures at a particular point in time would only provide a snapshot that did not reflect the fact that adjustments for optimism bias may be reduced as more reliable estimates of specific risks are made. (4) The DLUHC has already made a large amount of information about the plans and the proposed design publicly available. Before submitting a planning application, the DLUHC consulted widely on the proposed design. Two public exhibitions were held in Westminster in September and December 2018 and the project team met with a wide range of stakeholders, including faith leaders, residents’ groups, and survivors. All information relevant to the planning application for the site was previously available for inspection on Westminster City Council’s planning portal and continues to be available there. The fact that NAO were able to report to the public about the project shows that it has been z transparent process. Transparency does not remove the need for ministers to have a safe space when making policy decisions that are still being formulated. (5) The public interest generally said to be embraced by this head of exemption is that disclosure of the deliberative process whilst it is being undertaken will cramp the ability of those engaging in it to freely explore the full range of options. Since the decisions of the First-Tier Tribunal (Information Rights) in 2020 referred to in paragraph 11 of the Commissioner’s Decision Notice dated 11 April 9

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