Decision
Right to Know CLG and DAA Public Limited Company
From Office of the Commissioner for Environmental Information (OCEI)
Case number: OCE-154319-Y8Z5P3
Published on
From Office of the Commissioner for Environmental Information (OCEI)
Case number: OCE-154319-Y8Z5P3
Published on
Whether the DAA was justified in refusing access to environmental information under articles 8(a)(ii), 9(1)(b) and 9(1)(c) of the AIE Regulations
27 August 2025
1. On 26 September 2024, the appellant submitted the following request to the DAA:
“- a copy of any correspondence between DAA and UEFA with regard to the provision of flight slot guarantees for the UEFA* Euro 2028 tournament.
“- a copy of any records held in the email account of the DAA CEO referring or relating to the availability of flights or pressures arising from the passenger cap and their impact on Ireland's hosting of UEFA Euro 2028 games. This part of the request to cover the calendar year 2024 up until today's date.”
*Union of European Football Associations
2. By way of background, according to widely available media reports, Ireland is due to host six of UEFA’s EURO 2028 tournament’s matches at Dublin’s Aviva Stadium, to be renamed Dublin Arena for the duration of the tournament, which is tentatively due to be held between 9 June and 9 July 2028. According to a press release of 13 October 2023 on the UEFA website , UEFA’s executive committee appointed the football associations of Ireland and each of the four nations of the United Kingdom as joint hosts of the EURO 2028 tournament.
3. On 25 October 2024, the DAA issued its decision letter to the appellant, identifying two records relevant to the request and refusing to release them under articles 8(a)(ii) and 9(1)(b) of the AIE Regulations, having determined that the public interest in non-disclosure outweighed the public interest in release, pointing to the potential adverse effects on, respectively, the interests of third parties who provided information voluntarily without consent for its release and the course of justice.
4. On the same day, the appellant requested an internal review of the DAA’s first-instance decision.
5. On 22 November 2024, the DAA issued its internal review decision to the appellant, affirming the original decision-maker’s decision and clarifying that one of the records identified in that letter consisted of an email chain comprising 31 email exchanges between the DAA and UEFA. Notwithstanding this fact, the email chain continued to be refused under article 8(a)(ii).
6. On 6 December 2024, the appellant submitted an appeal to this Office against the DAA’s internal review decision, expressing dissatisfaction with the way in which the DAA had explained and reasoned its decision, and the lack of information regarding whether the DAA had contacted UEFA about the request. As shall be seen further below, the DAA did contact UEFA about the request and release of the information requested.
7. I have now completed my review of the appeal under article 12(5) of the AIE Regulations. In carrying out my review, I have had regard to the submissions made by the appellant and the DAA to this Office. In addition, I have had regard to:
• (the “AIE Directive”), upon which the AIE Regulations are based;
• the 1998 United Nations Economic Commission for Europe Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (the “Aarhus Convention”);
• The Aarhus Convention—An Implementation Guide (Second edition, June 2014) (the “Aarhus Guide”); and
• The Guidance document provided by the Minister for the Environment, Community and Local Government on the implementation of the AIE Regulations (the “Minister’s Guidance”).
• A decision of the Court of Justice of the European Union (CJEU) in Case C-619/19 Land Baden-Württenberg v. DR (Land Baden-Württenberg)
8. What follows does not comment or make findings on each and every argument advanced but I have considered all materials received in the course of the investigation and the proceedings.
9. The scheme of the AIE Regulations, and of the AIE Directive, makes it clear that there is a presumption in favour of release of environmental information. Subject to that presumption, a public authority may refuse to release environmental information where an exemption under articles 8 or 9 applies and the interest in maintaining that exemption outweighs the public interest in disclosure.
10. The original decision letter issued by DAA appears to refuse both records by relying on article 8(a)(ii) and 9(1)(b). However, in its submissions to this Office, the DAA states that“[o]ne record has also been refused under the AIE Regulations pursuant to Article 9(1)(b)” , which gives to understand that this latter record, and only this record, has been refused under article 9(1)(b) in addition to article 8(a)(ii). The schedule of records that issued to the appellant explains that the Outlook email exchange of emails has been refused under both articles, whereas the Airport Agreement has been refused only under article 8(a)(ii). However, the DAA’s submissions to this Office, when explaining that one of the records has been additionally refused under article 9(1)(b), refers to the inappropriateness of“correspondence and documentation regarding the Terminal Cap and issues inextricably linked to this case, to be released while the issue remains in a statutory process.” The reference to both“correspondence” , presumably the Outlook exchange of emails, and to“documentation” , presumably a reference to the Airport Agreement, gives to understand that both records refused have been withheld by the DAA under article 9(1)(b). Due to this confusion, my analysis below will consider the application of both articles 8(a)(ii) and 9(1)(b) to each of the withheld records.
11. DAA consulted with UEFA as part of its decision-making process on this request. UEFA claim that the information at issue is“commercially sensitive” and“subject to [a] confidentiality undertaking between the FAI, Dublin Airport and UEFA” and considers that“UEFA would be affected by the disclosure of this information” [email of 21 October 2024 from UEFA’s consultancy firm to the DAA, a copy of which was provided to this Office]. While DAA did not make any submissions as to whether 9(1)(c) applies to the information sought, I consider it appropriate for me to do so in this decision.
12. I will also note that the record containing the email exchanges in fact contains 28 emails, rather than 31 as referenced by DAA in its internal review decision. DAA have confirmed that this was a clerical error.
13. In accordance with article 12(5) of the AIE Regulations, my role is to review the public authority’s internal review decision and to affirm, annul or vary it. Where appropriate in the circumstances of an appeal, I will require the public authority to make available environmental information to the appellant.
14. I consider it appropriate to note, in respect of the confidentiality undertaking that UEFA has referred to, that the Airport Agreement allows for disclosure of confidential information contained in the agreement “as required by applicable laws.” I deem that the AIE Regulations, emanating as they do from both the AIE Directive and the UN Aarhus Convention, are laws encompassed within that clause.
15. Having reviewed the Airport Agreement, which is divided into chapters each dealing with a specific matter, it is apparent that while certain of the information in the document is, in fact, related to the request, most of the information contained in the document is not within its scope. I consider that information in the Airport Agreement that is relevant to the request can be separated out or redacted from the remainder of the document, in conformity with article 10(5) of the AIE Regulations, and my analysis will confine itself only to that part of the Airport Agreement that is relevant to the request. The part of the Agreement that is relevant to the request consists of:
i. Clauses 2.6 to 2.9 inclusive of the Agreement, under the heading “Airport Passenger Capacity”;
ii. The first two pages of the Agreement which give details of the parties that are signatories to the Agreement;
iii. The signatories page; and
iv. The Appendix B page and letter attached thereto.
16. I note that the appellant was informed during the course of the review of this appeal that only certain parts of the Airport Agreement were considered by the investigator to be within the scope of the request. Its observations were solicited in the event that the Commissioner should decide to separate out those parts from the rest of the agreement and direct release only of those parts. The appellant responded to say that it was“happy the out of scope material can be treated as such and set aside for the purposes of the decision.” I take the opportunity to note here also that the appellant has also made known to this Office that it is happy to receive the email communications that are relevant to the request in redacted form to exclude release of the personal information of any third party identified in them.
17. Article 9(1)(c) of the AIE Regulations permits a public authority to refuse to make environmental information available where disclosure of the information requested would adversely affect“commercial or industrial confidentiality, where such confidentiality is provided in national or Community law to protect a legitimate economic interest” . This is subject to article 10 of the AIE Regulations, which requires a public authority to consider each request on an individual basis and to weigh the public interest served by disclosure against the public interest served by refusal, interpreting the grounds for refusal on a restrictive basis having regard to the public interest served by disclosure.
18. From the text of the provision it is clear that engagement of the exemption provided in the article requires evidence of four essential elements:.
a. The confidentiality of the information must be provided for by law.
b. The confidentiality must be commercial or industrial.
c. The confidentiality must protect a legitimate economic interest.
d. The confidentiality would be adversely affected by disclosure.
19. In order to show that the confidentiality is protecting a legitimate economic interest, there must be some adverse effect on that interest if the information were to be disclosed.
20. UEFA claim that the information at issue is“commercially sensitive” and “subject to [a] confidentiality undertaking between the FAI, Dublin Airport and UEFA” and considers that “UEFA would be affected by the disclosure of this information” [email of 21 October 2024 from UEFA’s consultancy firm to the DAA, a copy of which was provided to this Office]. Whilst it is not clear from this statement whether the information to which it refers is to one or both of the records refused, for purposes of this decision I deem it appropriate to consider that it is to both the email exchange and the Airport Agreement that have been identified by the DAA as the information relevant to the request. Whilst this UEFA communication refers to“commercially sensitive information” and“confidentiality” , as noted above the DAA has made no specific reference to any provision in the AIE Regulations that it could potentially rely on under such a category in order to prevent release of the information. However, for the sake of completeness, I consider it appropriate to assess whether the article has any application to the information at issue in this case.
21. While UEFA asserts that the information is“commercially sensitive” , it gives no detail in relation to which specific parts of either refused record that might have this quality. While I accept that the agreement itself and communications between the parties that revolve around it might be commercial in nature, as each party to the agreement are arguably engaged in commercial activities, a necessary prerequisite to application of article 9(1)(c) is that information that is asserted to be covered by it is sufficiently identified and specific. For example, while the agreement may be commercial in nature, it does not follow that each and every part of it can be said to be commercially sensitive. This is equally the case with the email exchanges. Moreover, neither UEFA nor the DAA has (i) pointed to any law that might provide for the confidentiality of the information at issue (ii) identified any legitimate economic interest that might be affected by release of the information; or (iii) explained the nature of any adverse effects that might arise from its release or how these may come about, all of which factors must be shown to exist before the article may be engaged. I note that the agreement has been concluded between the parties and I consider that the release of any of the requested information will not have any adverse effect on the legitimate economic interests of either party.
22. I note also that the DAA, whose principal activities include the operation and management of both Dublin and Cork airports (according to https://www.daa.ie/ ), has responsibility for the vast bulk of inbound and outbound flights in Ireland and as such has little or no competition, by reason of which the release of any commercially confidential information in the two refused records would have, in my view, little or no adverse effect on any of its legitimate economic interests. Equally, UEFA, the governing body of football in Europe and sole organiser of the Euro 2028 tournament (see here ), faces no competition in this commercial enterprise, by reason of which the release of any commercially confidential information in the two refused records, in my view, would have little or no adverse effect on any of its legitimate economic interests. Accordingly, given all of the above, I am satisfied that neither the DAA nor UEFA has demonstrated that article 9(1)(c) has application to the information at issue in this appeal. I note, finally, that it is not sufficient that a public authority simply cite the article in order to allow it to rely on the exemption. Rather, as well as these steps, it must provide evidence, as set out by the CJEU at paragraph 69 of Land Baden-Wurttemberg of the specific and actual adverse effects that will result from the release of the information.
23. This article provides that a public authority shall not make available environmental information where disclosure of the information—
“(a) would adversely affect—
(i)….
(ii) the interests of any person who, voluntarily and without being under, or capable of being put under, a legal obligation to do so, supplied the information requested, unless that person has consented to the release of that information”
24. Article 8(a)(ii) seeks to implement Article 4(2)(g) of the AIE Directive, which is in turn based on Article 4(2)(g) of the Aarhus Convention. I note that the Aarhus Implementation Guide, quoting from the Convention, refers to “third party” rather than to the term “person” that is used in both the AIE Directive and Regulations, and states that“a ‘third party’ is a person not a party to a particular agreement or transaction, but a person who may have rights or interests therein….In the case of access to information, the ‘transaction’ will generally be the information request.” The Minister’s Guidance on the implementation of the AIE Regulations suggests that this“provision is intended to safeguard informal and voluntary communications between public authorities and third parties which are essential to good public administration generally.”
25. DAA has sought to apply article 8(a)(ii) to both records relevant to this request.
26. Record 1 is a series of email exchanges between DAA and UEFA. It could be said, in the broadest sense, that each of these emails contains information provided by UEFA to DAA. I note that in this instance, UEFA, while being under no legal obligation to enter into an agreement with the DAA, communicated voluntarily with DAA in the context of contractual negotiations with a view to formulating and concluding a formal agreement with the DAA in order that the latter might provide certain services at Dublin Airport to facilitate the holding of matches in Dublin as part of the EURO 2028 tournament. However, I have reviewed the emails in question, and I am not satisfied that this is the type of information that can correctly come within article 8(a)(ii) of the AIE Regulations. I am mindful of my obligation to interpret exemptions in a restrictive basis as set out in article 10(4), and I am not satisfied that the information contained in record 1 can be described as ‘information supplied’ to DAA by UEFA. I am not satisfied that this record can be considered to contain “informal and voluntary communications” between a third party and a public authority as set out in the Minister’s Guidance or that these communications are the type that are essential to good public administration generally. To interpret article 8(a)(ii) as covering all communications between third parties would be overly broad and not in keeping with the purpose of the AIE Regulations and Directive.
27. Record 2 is a copy of the agreement reached between UEFA and DAA in respect of services to be provided in the context of the football tournament. While this agreement may have been reached based on information provided by both parties, I am equally not satisfied that the agreement can be described as information “supplied” to DAA by UEFA.
28. I am therefore not satisfied that article 8(a)(ii) applies to either of the records relevant to this request. However I will note that article 8(a)(ii) also requires that the release of the information sought would have an adverse effect on the interests of the person supplying the information, and as I have found above in relation to article 9(1)(c), I am not satisfied that the release of the information sought would adversely affect the interests of UEFA or of the DAA.
29. In its original decision letter to the appellant, the DAA indicated that a third party had deemed that the information identified as relevant to the request was commercially sensitive, was subject to a confidentiality undertaking between the FAI (Football Association of Ireland), Dublin Airport, and UEFA, and that UEFA [the identified third party]“could be negatively affected by the disclosure of this documentation. As such they [UEFA] did not authorise the release of documents. ” My understanding is that the documentation/documents referred to here are each of the two records withheld, namely the emails contained in the email exchanges between the DAA and UEFA, identified in the schedule of records issued to the appellant as a (Microsoft) Outlook document and denominated “Euro 28 Agreement Finalisation – Dublin” (record 1) and a pdf document identified in that same schedule of records as “Euro2028-2032-UKI-AirportAgreement-DUB_Fullysigned” (record 2, the Airport Agreement).
30. I note that this last record, the Airport Agreement, is attached to the most recent email, of 1 July 2024, in the email thread that constitutes the first of the two records refused. This email is from legal counsel of a third party organisation (not UEFA) and who at the date of the email was part of a transition team apparently set up in the aftermath of the successful bid by Ireland and the UK to host the EURO 2028 tournament. The email is addressed to an officer of the DAA, but not to the chief executive officer. This detail is significant, as I note further that the second part of the appellant’s request was for relevant“records held in the email account of the DAA CEO” . Whilst the document attached to this email has been identified by the DAA as relevant to the appellant’s request, it is not readily apparent to me that it is within scope of the request, as it does not seem to be a record “held in the email account of the DAA CEO”. However, I accept that the CEO may have been copied into the email as a ‘blind’ recipient, for which reason the name of the CEO would not appear on any electronic or paper version of the email. Moreover, as the DAA has identified this record as relevant to the request, I accept that this must be the case, and that the document attached to the email of 1 July 2024 (namely, the second record refused) has been retrieved from the CEO’s email account and is thus within scope of the request. Further to support this position is the fact that the DAA has advanced no reason to indicate that this record is out of scope of the request.
31. The other emails in the thread are between, variously and among others, officers of the DAA and staff members of UEFA’s consultancy firm, which according to the DAA submissions made to this Office,“works with UEFA on various projects, including event planning and logistics for the UEFA EURO 2028” tournament. To the extent that these emails are either from or to staff members of UEFA’s consultancy firm that is representing UEFA in the exchanges, I accept that they are, as indicated in the DAA’s internal review decision to the appellant, emails between the DAA and UEFA. Certain of the emails are either between these persons and other third parties or have been copied to these third parties, whose identity for the purposes of this decision it is not necessary for me to identify.
32. In its submissions to this Office dated 3 January 2025, the DAA relied, inter alia, on article 8(a)(ii) to exempt the two withheld records from release. This article requires public authorities not to make available environmental information where disclosure would adversely affect—
“the confidentiality of personal information relating to a natural person who has not consented to the disclosure of the information, and where that confidentiality is otherwise protected by law”.
33. In those submissions, the DAA states that the third party, UEFA, did not consent to its release, indicating, according to correspondence received by the DAA from it, that it did not agree with the disclosure of the documents.
34. A core requirement to enable a public authority to rely on any of the provisions in article 8 of the AIE Regulations is that it provide evidence that disclosure of information that it is withholding would adversely affect the particular interest protected by the sub-article of the provision it relies on, in this case sub-article (ii), namely the interests of a person who has voluntarily supplied it with information with no legal obligation to do so and who has not consented to its release. Whilst the person in this case is the third party identified by the DAA, that is, UEFA, neither this entity nor the DAA has identified any adverse effect consequent upon release of either of the withheld records.
35. When informed of the receipt of this appeal by this Office, the DAA was invited to submit detailed submissions in support of its decision to refuse the information requested and to consider it as the final opportunity to explain and justify the basis of its decision. Whilst it has provided this Office with submissions, it has submitted no explanation relating to the adverse effects that would result following release of the information it has refused to release, except to allude, in its original decision letter in its reference to the public interest balancing test of article 10(3) to“the potential adverse effects on the course of justice and the interests of third parties”. As the furnishing of evidence of the likely specific and actual adverse effects following release of the information has not been made by the DAA in this case, I am not in a position to accept its reliance on article 8(a)(ii) to withhold the information. Accordingly, its reliance on this article necessarily fails.
36. As noted above, apart from one substantive section of the Airport Agreement (see i. below), the remainder of this document is out of scope of the request as it is not relevant to it. As I consider that this section can be separated out or redacted from the remainder of the document, in conformity with article 10(5) of the AIE Regulations, the DAA is directed to release this section, as well as certain incidental sections which will give context to that section and to the agreement. In summary, the DAA is directed to release the following parts of the agreement:
i. Clauses 2.6 to 2.9 inclusive of the Agreement, under the heading “Airport Passenger Capacity”
ii. The first two pages of the Agreement which give details of the parties that are signatories to the Agreement;
iii. The signatories page; and
iv. The Appendix B page and letter attached thereto.
37. At paragraph 50 below, I have set out the appropriate redactions that should be made to the emails in the Outlook email exchange that constitutes record 1.
38. As the DAA has not established the existence of adverse effects in respect of release of the withheld information under article 8(a)(ii), by which reason it cannot rely on it, there is no requirement to apply the public interest balancing test to its release, as I have established that the information relevant to the request is to be released.
39. Article 9(1)(b) of the AIE Regulations provides that a public authority may refuse to make available environmental information where disclosure of the information would adversely affect—
“the course of justice (including criminal inquiries and disciplinary inquiries)”.
40. Article 9(1)(b) seeks to implement Article 4(2)(c) of the AIE Directive, which is in turn based on Article 4(4)(c) of the Aarhus Convention. I note that the Aarhus Guide interprets “the course of justice” as referring to“active proceedings within the courts” . The Minister’s Guidance on the implementation of the AIE Regulations suggests that the course of justice includes matters“relating to anything which is the subject matter of any legal proceedings, or of any formal inquiry (whether past or present), or any preliminary investigation”.
41. As in the case of article 8(a)(ii) analysed above, the wording of the article makes it clear that there must be some adverse effect on the course of justice in order for the exception to apply. Accordingly, when relying on this provision a public authority must set out the reasons why it considers that the disclosure of the information at issue could specifically and actually undermine the course of justice as set out by the CJEU at paragraph 69 of Land Baden-Wurttemberg. The risk of the course of justice being undermined must be reasonably foreseeable and not purely hypothetical.
42. Article 9(1)(b), when considered applicable to any particular circumstance, as with other exempting provisions must be read alongside article 10, which provides for certain limitations on the ability of a public authority to refuse environmental information. Article 10(3) clearly provides that the request must be considered on an individual basis with the public interest served by disclosure weighed against the public interest served by refusal. Also, article 10(5) provides that nothing in articles 8 or 9 shall authorise a public authority not to make available environmental information which, although held with information to which article 8 or 9 relates, may be separated from such information.
43. The requirements outlined above mean that a public authority must examine the information in question before it can invoke grounds for refusal of that information. Where grounds for refusal are identified, the information should be examined to determine whether certain information may be released without adversely affecting the course of justice. I note that the records at issue are the Outlook exchange of emails and the Airport Agreement. I note also that the second part of the appellant’s request is for“records held… referring or relating to the availability of flights or pressures arising from the passenger cap and their impact on Ireland's hosting of UEFA Euro 2028 games”.
44. In respect of the Airport Agreement, I have already established at paragraph 15 above that much of it, not being relevant to the request, may be redacted from that which is relevant, in conformity with article 10(5) of the Regulations.
45. This leaves me to consider whether the email exchange as a whole or any part of it, and the Airport Agreement or any part of it can be considered to fall under article 9(1)(b) by reason of the statutory process to which the DAA refers in both its original decision letter and its submissions to this Office, namely, the“active Section 152 of the Planning & Development Act 2000 as amended” , whereby the DAA contends that the information withheld falls within the remit of the article which explicitly refers to“the course of justice (including criminal inquiries and disciplinary inquiries)”.
46. In its original decision letter to the appellant of 25 October 2024, the DAA gives, as the reason for its refusal to release information under article 9(1)(b), that the“32m [32 million] terminal cap at Dublin Airport (the “Terminal Cap”) is subject to an active Section 152 of the Planning & Development Act 2000 as amended. Consequently, it would not be appropriate for correspondence and documentation regarding the Terminal Cap and issues inextricably linked to this case, to be released while the issue remains in a statutory process.” Its internal review decision letter of 22 November 2024 merely affirms the first instance decision without giving more detail on the reasons for refusal. It is dismaying that, for the purposes of the review of this appeal, the DAA has given no further detail in relation to what it terms the“active section 152 of the Planning and Development Act 2000” , when the provision of greater detail would accelerate the resolution of this appeal and could conceivably help to support the DAA’s decision. As matters stand, with only a generic reference in the DAA’s statement above to“a statutory process” , the Commissioner has no information at hand that could serve to support a decision of his to affirm the DAA’s decision to refuse the information requested. As stated above, the DAA has had ample opportunity to furnish to this Office sufficient detail in relation to its decision to refuse that information but has not done so.
47. For the reader who may have little or no knowledge of what the cited “terminal cap” is, it refers, as referenced in this Irish Times article of 30 August 2007, to a cap or limit of 32 million passengers passing through terminals 1 and 2 of Dublin Airport, imposed as one of many conditions attached by An Bord Pleanála in 2007 to its grant of permission to the DAA to progress construction of a new second terminal at Dublin Airport in view of potential capacity constraints in road transportation in and around the airport arising from the pending opening of the new terminal. Extensive media reports in the past 18 months refer to attempts by the DAA to increase the passenger cap to 40 million per annum and, in more recent months, pending a decision on the matter by Fingal County Council, to an interim 36 million passengers. The section 152 action to which the DAA makes reference relates to that section of the Planning and Development Act 2000, as amended, which provides that where—
(a) a representation in writing is made to a planning authority by any person that unauthorised development may have been, is being or may be carried out, and it appears to the planning authority that the representation is not vexatious, frivolous or without substance or foundation, or
(b) it otherwise appears to the authority that unauthorised development may have been, is being or may be carried out, the authority shall issue a warning letter to the owner, the occupier or any other person carrying out the development and may give a copy, at that time or thereafter, to any other person who in its opinion may be concerned with the matters to which the letter relates.
48. As this Office has been given no detail in relation to the stage at which this action is at, nor relevant reference numbers by which to track progress, it is not possible for the Commissioner to ascertain whether the action may or may not be adversely affected by the release of the requested information. The DAA, apart from stating that“it would not be appropriate” to release information“regarding the Terminal Cap and issues inextricably linked to this case” has given no explanation of the nature of the adverse effects that could occur upon release of the information nor, indeed, of the way in which any such adverse effects would manifest themselves. As in the case of articles 8(a)(ii) and 9(1)(c) above, evidence of the likely specific and actual adverse effects is an essential prerequisite which a public authority must produce in order to avail of this exemption. As no such evidence has been produced, I am unable to affirm the DAA’s decision based on reliance on this article.
49. I am satisfied that the DAA has not demonstrated that articles 8(a)(ii), 9(1)(b) or 9(1)(c) can be engaged such as to withhold the information requested.
50. Having carried out a review under article 12(5) of the AIE Regulations, I annul DAA’s decision to refuse the information sought under articles 8(a)(ii), 9(1)(b) and 9(1)(c) and direct its release to the appellant, subject to the redactions outlined above in respect of the Airport Agreement. As regards the Outlook email exchanges, which contain the names and email addresses of persons who are neither DAA nor UEFA officials and some of which pertain to third parties, I direct that these, too, be redacted, but that the name of the consultancy firm that represents UEFA in the email exchanges should not be redacted, as this is a firm representing a party to the Airport Agreement.
51. A party to the appeal or any other person affected by this decision may appeal to the High Court on a point of law from the decision. Such an appeal must be initiated not later than two months after notice of the decision was given to the person bringing the appeal.
______________________
Julie O’Leary
On behalf of the Commissioner for Environmental Information