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ORDER BACKGROUND: The Corporation of the Town of Markham (the Town) received a request under the Municipal Freedom of Information and Protection of Privacy Act (the Act ) for access to the following records: 1. The Insurance Advisory Organization report on the current operational status of the Fire Department in Markham 2. The M.M. Dillon Report concerning the location of the fire stations in the Town of Markham The Town denied access to the records, claiming section 11(f) of the Act . The requester appealed the Town's decision. The record responsive to Part 1 of the request (Record 1) consists of a three page letter dated December 20, 1991 with four attachments: one page titled "Survey Recommendations", one page titled "Water Supply", two pages titled "Fire Department - Fire Suppression Forces", and a three page table. The record responsive to Part 2 of the request (Record 2) is titled "Town of Markham Fire Station Location Study". This record is 112 pages in length and is made up of a title page, a table of contents, 12 chapters, a two page table and 64 pages of "Figures". Mediation of the appeal resulted in the Town reconsidering its position. A revised decision was issued by the Town which granted the appellant partial access to both records. With respect to Record 1, access was denied to page 2 of the letter, the identity of the author of the letter (found on page 3 of the letter), the page titled "Survey Recommendations", and the two pages titled "Fire Department - Fire Suppression Forces". With respect to Record 2, access was denied to the title page, table of contents, part of Chapter 3, Chapters 7, 9, 10, 11 and 12, and the table and figures. Access was denied pursuant to section 11(f) of the Act and additional exemptions under sections 11(e) and (g) were claimed by the Town. The appellant indicates that he does not require the identity of the author of Record 1. Accordingly, the severed portion of page 3 of the letter of Record 1 and the name of the author as it appears on the document titled "Survey Recommendations" of Record 1 are not at issue in this appeal. Further attempts to mediate the appeal were not successful, and notice that an inquiry was being conducted to review the Town's decision was sent to the Town and the appellant. Written representations were received from both parties. PRELIMINARY MATTER: In his representations, the appellant states that the Town has not complied with section 22 of the Act , because it failed to include the reason the exemptions apply to the withheld records in its decision. Section 22(1)(b) of the Act reads as follows: Notice of refusal to give access to a record or part under section 19 shall set out, (b) where there is such a record, (i) the specific provision of this Act under which access is refused, (ii) the reason the provision applies to the record, (iii) the name and position of the person responsible for making the decision, and (iv) that the person who made the request may appeal to the Commissioner for a review of the decision. Section 22(1)(b) of the Act is identical to section 29(1)(b) of the provincial Freedom of Information and Protection of Privacy Act . In Order 158 former Commissioner Sidney B. Linden addressed the requirements of section 29(1)(b)(ii). He pointed out that specifying which part of a provision applies to a record is not the equivalent of providing the reason a provision applies, as required by section 29(1)(b)(ii). At page 4 of Order 158, he stated: In my view, a head is required to provide a requester with information about the circumstances which form the basis for the head's decision to deny access. The degree of particularity used in describing the record at issue will impact on the amount of detail required in giving reasons, and vice versa. For example, if a record is described not in general terms, but rather as a memo to and from particular individuals on a particular date about a particular topic, then the reason the provision applies to the record could be given in less detail than would be required if the record were described only as a memo. The end result of either approach is that the requester is in a position to make a reasonably informed decision as to whether to seek a review of the head's decision. The Town's decision in the present appeal simply states the wording of sections 11(e), (f) and (g) without further reasons for applying the exemptions. In my view, this is not sufficient to satisfy the requirements of section 22(1)(b)(ii) of the Act . However, I do not see that any purpose would be served in ordering the Town to provide a proper notice of refusal letter at this stage of the appeal. Accordingly, I will proceed to dispose of the issues relating to access to the records. I remind the Town, however, of the importance of issuing proper and comprehensive notice of refusal letters when responding to requests under the Act . ISSUE: The issue arising in this appeal is: A. Whether the discretionary exemptions provided by sections 11(e), (f) and/or (g) apply. SUBMISSIONS/CONCLUSIONS: ISSUE A: Whether the discretionary exemptions provided by sections 11(e), (f) and/or (g) apply. The Town submits that sections 11(e), (f) and (g) apply to the information severed from the records. These sections read: A head may refuse to disclose a record that contains, (e) positions, plans, procedures, criteria or instructions to be applied to any negotiations carried on or to be carried on by or on behalf of an institution; (f) plans relating to the management of personnel or the administration of an institution that have not yet been put into operation or made public; (g) information including the proposed plans, policies or projects of an institution if the disclosure could reasonably be expected to result in premature disclosure of a pending policy decision or undue financial benefit or loss to a person; The Town submits: We are of the opinion that the undisclosed portions of the [records] fully qualify as disclosure exemptions pursuant to the discretionary exemptions provided in the noted subsections of s. 11. Furthermore, the decision to sever
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