the surveillance and tried to argue that it was justified under RIPA, but in a subsequent ruling by the Investigatory Powers Tribunal – its first ever ruling – the surveillance was deemed to be unlawful. The same council put fishermen under covert surveillance to check for the illegal harvesting of cockles and clams in ways that are regulated by RIPA. David Smith, deputy commissioner at the ICO (Information Commissioner's Office) stated that he was concerned about the surveillance which took place in Poole. Other councils in the UK have conducted undercover operations regulated by RIPA against dog fouling and fly-tipping. In April 2016, 12 councils said that they use unmanned aerial vehicles for "covert operations", and that such flights are covered by the Regulation of Investigatory Powers Act 2000. Despite claims in the press that local councils are conducting over a thousand RIPA-based covert surveillance operations every month for petty offences such as under-age smoking and breaches of planning regulations, the Office of Surveillance Commissioners' last report shows that public bodies granted 8,477 requests for Directed Surveillance, down over 1,400 on the previous year. Less than half of those were granted by Local Authorities, and the commissioner reported that, "Generally speaking, local authorities use their powers sparingly with over half of them granting five or fewer authorisations for directed surveillance. Some sixteen per cent granted none at all." In June 2008, the chairman of the Local Government Association, Sir Simon Milton, sent out a letter to the leaders of every council in England, urging local governments not to use the new powers granted by RIPA "for trivial matters", and suggested "reviewing these powers annually by an appropriate scrutiny committee". Especially contentious was Part III of the Act, which requires persons to (allegedly) self-incriminate by disclosing a password to government representatives. Failure to do so is a criminal offence, with a penalty of two years in jail or five years in cases involving national security or child indecency. Using the mechanism of secondary legislation, some parts of the Act required activation by a ministerial order before attaining legal force. Such orders have been made in respect of the relevant sections of Part I and Part II of the RIP Act and Part III. The latter became active in October 2007. The first case where the powers were used was against animal rights activists in November 2007. Identification of journalists' sources In