reasonably and was reasonable in substance and that these exemptions are engaged. The PIBT 147. The Appellant refers to the PIBT in particular in part 7 of the GoA (A103107). In summary as regards the PIBT for section 36(2)(c) FOIA his position is as follows: as regards UoE’s argument that there is a public interest in being able to continue to function etc he says:“Yes, but what on earth does this have to do with the proposed FOIA disclosure? The University here insinuates that the proposed disclosure would somehow undermine its ability to “teach, research and engage with its communities and stakeholders” and that it would impose a large financial burden; but it does not give even the slightest explanation of the alleged causal link behind these insinuations. These claims are simply plucked out of the air; they go far beyond even the four harms that the University has claimed — claims that themselves are unsupported by any causal link, as I have shown in Sections 5.1–5.4.”  to UoE’s assertion that there would be disruption meaning resources being spent on these matters rather than being directed towards education and/or research he says:“Once again, there is not one iota of evidence or argument as to why disclosure of the Facts and Evidence section of the Report — with, of course, all names and identifying information carefully redacted — would lead to “claims and complaints” (nor any indication of the nature or probable validity of those claims and complaints), much less to “disruption”. All this is pure speculation, unsupported by any evidence or plausible causal link; it recycles and then embellishes the University’s claims that I have already refuted in Section 5.1.”  as regards UoE’s claim that there would be damage to UoE’s reputation which would impact staff and student recruitment he says:“it is, indeed, quite possible that the University — or to be more precise, some of its current high officials, which is a very different thing — might suffer some (limited) reputational damage from the disclosure of the Facts and Evidence section of the Report if those facts turn out to be sufficiently damning. But in that case I can hardly see why it is in the public interest that these officials be protected from public accountability for their mistakes” 41