Under the
The Virginia Freedom of Information
Act (FOIA) is largely a procedural act, and §§ 2.2-3704 and 2.2-3704.01 of the
Code of Virginia guide users on how to make or respond to a FOIA request for
public records. This outline explains these procedural requirements and
provides practical advice for adhering to FOIA when making or responding to a
request. Further detailed guidance regarding charges for the production of
public records is provided in a separate document entitled "FOIA Charges
Guide," which can be found on the FOIA Council website.
What is
a public record under FOIA?
A "public record" is any
writing or recording, in any format, prepared or owned by, or in the possession
of a public body or its officers, employees, or agents in the transaction of
public business. For example, public records may be in the form of handwritten
notes, typewritten documents, electronic files (including email and social
media posts), audio or video recordings, photographs, or any other written or
recorded media.
Are
draft or preliminary versions also considered public records?
Yes. The definition of "public
record" does not distinguish between draft or preliminary versions and
final versions, so both are considered public records under FOIA.[1]
Who may
request records under FOIA?
· Citizens
of the Commonwealth;
·
Representatives of newspapers and
magazines with circulation in the Commonwealth; and
·
Representatives of radio and television
stations broadcasting in or into the Commonwealth.
Must a
request mention "FOIA" specifically?
No. The request does not need to mention
FOIA in order to invoke its provisions or to impose the time limits for
response by a public body.
Must a request be made in writing?
No. A written request is not
required. However, as a practical matter, it is suggested that the request be
made in writing, whether in a paper or electronic format. A written request
provides recourse for both parties.[2]
May a public body require a requester to
fill out a request form?
No. A public body may develop a
request form that it asks requesters to fill out, but a public body may not
insist that its form be used before it begins work on a FOIA request.
NOTE: It is suggested that if the requester refuses
to fill in the form or to put the request in writing, the public body should
fill out its own form—remember, writing is recourse.[3]
May a
public body require a requester to provide his name and legal address?
Yes. A
public body may require a requester to provide his name and legal address
before processing a FOIA request.
NOTE: This is a tool a public body may use, but FOIA does not mandate that
public bodies get identification first.[4]
For more
practical tips on requesting public records, see the separate guide "Best
Practices for Making Requests for Public Records" available on the FOIA
Council website.
III. Responding to a Request
for Records
How
long does a public body have to respond to a request?
A public body must respond within five
working days of receipt of the request.
NOTE: Count the day after receipt as Day 1.[5]
REMEMBER: Failure
to respond to a request for records shall be deemed a denial of the request and
constitutes a violation of FOIA.[6]
What
are the permissible responses to a request?
After
receiving a request, a public body must make one of the five responses allowed
by FOIA:
1.
The custodian provides the requested
records to the requester;
2.
The requested records are entirely
withheld because their release is prohibited by law or the custodian has
exercised his discretion to withhold the records in accordance with FOIA;
3.
The requested records are provided in part
and are withheld in part because the release of part of the records is
prohibited by law or the custodian has exercised his discretion to withhold a
portion of the records in accordance with FOIA;
4.
Notice is
provided that the requested records could not be found or do not exist.
However, if the public body that received the request knows that another public
body has the requested records, the response shall include contact information
for the other public body; or
5.
It is not practically possible to provide
the requested records OR to
determine whether they are available within the five-work-day period prescribed
by FOIA, and the public body needs an additional seven work days, or in the
case of a request for criminal investigative files pursuant to § 2.2-3706.1,
60 work days, in which to provide one of the four preceding responses.[7]
When does a response need to be
in writing?
If any part of the answer is "NO"
(i.e., response 2 or 3 above), the response must:
1.
Be in writing;
2.
Identify with reasonable particularity the
subject matter of withheld records; and
3.
Cite, as to each category of withheld
records, the specific section of the Code of Virginia that authorizes the
records to be withheld.
If the records are being entirely withheld
(i.e., response 2) then the response must also identify with reasonable
particularity the volume of the withheld records.
If the answer is "we cannot find it"
or "it does not exist" (i.e., response 4 above):
1.
The response must be in writing; and
2.
If the public body knows that another
public body has the records, the public body that received the request must
provide contact information for the other public body.
If the answer is "we need more time"
and the public body would like seven additional working days to respond (i.e.,
response 5 above), the response must:
1.
Be in writing; and
2.
Specify the conditions that make
production of the records within the five-work-day period impossible.
How does a public body respond if a record
contains exempt and nonexempt information?
Generally,
if a record contains exempt and nonexempt information, the public body must
release the record and delete or excise only the exempt portion of the record.
Must a public body create a record in
response to a FOIA request?
Generally,
a public body is not required to
create a new record if the requested record does not already exist. However, a
public body may abstract or summarize information under such terms and
conditions as agreed between the requester and the public body.[8]
How much may a public body charge for
producing records?
A public body may make reasonable charges
for its actual cost incurred in
accessing, duplicating, supplying, or searching for the requested records. Public
bodies are required to make all reasonable efforts to supply the requested
records at the lowest possible cost. A public body may not charge extraneous or
surplus fees unrelated to the production of the records.
NOTE: A public body cannot factor in expenses such
as overhead or the cost of benefits paid to employees. Charges for copies must
not exceed the actual cost of duplication.
NOTE: As of July 1, 2022, public bodies may not
charge for "scholastic records requested pursuant to subdivision A 1 of §
2.2-3705.4 that must be made available for inspection pursuant to the federal
Family Educational Rights and Privacy Act (20 U.S.C. § 1232g) and such requests
for scholastic records by a parent or legal guardian of a minor student or by a
student who is 18 years of age or older."
Are
cost estimates required?
If a requester asks that the public body
estimate the cost of supplying the requested records in advance, then the
public body must provide a cost estimate. The
five-working-day period to respond is tolled for the amount of time that
elapses between notice of the cost estimate and the response of the requester.
If the public body receives no response from the requester within 30 days of
sending the cost estimate, the request shall be deemed to be withdrawn. As
mentioned previously, further detailed guidance regarding charges for the
production of records is provided in the "FOIA Charges Guide."[9]
Can a
public body require advance payment?
When a public body determines in advance
that the charges for supplying the requested records are likely to exceed $200,
it may require the requester to pay a deposit before proceeding with the
request. This deposit may not exceed the amount of the advance determination,
and the public body must credit it toward the final cost of supplying the
records. If a public body asks for the advance deposit, the five-working-day
period to respond to the request is tolled until the deposit is paid.[10]
What can a public body do if a requester does not pay for records
provided under FOIA?
Before responding to a new request for
records, a public body may require the requester to pay any amounts owed to the
public body for previous requests for records that remain unpaid 30 days or
more after billing.
Do
these same requirements apply to a request for electronic records?
Yes. Like all other records, regardless of
format, a public body may only charge a reasonable, not to exceed actual, cost
for producing public records maintained in an electronic data processing system
or computer database. And like other records, when electronic records or
databases contain both exempt and nonexempt records, the public body must
supply the nonexempt information and may excise or delete the exempt
information. The excision of exempt fields from a database or the conversion of
data from one available format to another is not considered the creation of a
new record under FOIA.
A public body must
provide electronic records in any medium identified by the requester if that
medium is used by the public body in the regular course of business. If the
public body has the capability, this includes the option of posting the records
on a website or delivering the records to an email address. A public body is
not required to produce records in a format not regularly used by the public
body. However, a public body must make reasonable efforts to provide records in
any format under such terms and conditions as agreed between the requester and
the public body, including the payment of reasonable costs.[11]
For more information
on charges for public records, see the separate "FOIA Charges Guide"
available on the FOIA Council website.
APPENDIX
Records
Exemptions of General Applicability
FOIA contains over 150
exemptions for records. Although many of these exemptions apply to specific
agencies and to very specific types of records, there are several records
exemptions of general applicability that may be used by virtually all public
bodies. The most commonly used records exemptions of general applicability are
listed below with the corresponding statutory citation for reference.
§ 2.2-3705.1 (1): Personnel
information.
Provides an exemption for:
Personnel
information concerning identifiable individuals, except that access shall not
be denied to the person who is the subject thereof. Any person who is the
subject of such information and who is 18 years of age or older may waive, in
writing, the protections afforded by this subdivision. If the protections are
so waived, such information shall be disclosed. Nothing in this subdivision
shall be construed to authorize the withholding of any resumes or applications
submitted by persons who are appointed by the Governor pursuant to § 2.2-106 or
2.2-107.
No
provision of this chapter or any provision of Chapter 38 (§ 2.2-3800 et seq.)
shall be construed as denying public access to (i) contracts between a public
body and its officers or employees, other than contracts settling public
employee employment disputes held confidential as personnel records under §
2.2-3705.1; (ii) records of the name, position, job classification, official
salary, or rate of pay of, and records of the allowances or reimbursements for
expenses paid to, any officer, official, or employee of a public body; or (iii)
the compensation or benefits paid by any corporation organized by the Virginia
Retirement System or its officers or employees. The provisions of this
subdivision, however, shall not require public access to records of the
official salaries or rates of pay of public employees whose annual rate of pay
is $10,000 or less.
NOTE: In the
case Hawkins v. Town of South Hill (2022),
the Supreme Court of Virginia held that personnel information "means data,
facts, or statements within a public record relating to a specific government
employee, which are in the possession of the entity solely because of the
individual's employment relationship with the entity, and are private, but for
the individual's employment with the entity" and that such "data,
facts, and statements are private if their disclosure would constitute an 'unwarranted
invasion of personal privacy' to a reasonable person under the circumstances."
§ 2.2-3705.1 (2): Attorney-client
privilege.
Provides an exemption for:
Written
advice of legal counsel to state, regional or local public bodies or the
officers or employees of such public bodies, and any other information
protected by the attorney-client privilege.
§ 2.2-3705.1 (3): Attorney work
product.
Provides an exemption for:
Legal
memoranda and other work product compiled specifically for use in litigation or
for use in an active administrative investigation concerning a matter that is
properly the subject of a closed meeting under § 2.2-3711.
§ 2.2-3705.1 (4): Tests and
examinations. Provides an exemption for:
Any test
or examination used, administered or prepared by any public body for purposes
of evaluation of (i) any student or any student's performance, (ii) any
employee or employment seeker's qualifications or aptitude for employment,
retention, or promotion, or (iii) qualifications for any license or certificate
issued by a public body.
As used
in this subdivision, "test or examination" shall include (a) any
scoring key for any such test or examination and (b) any other document that
would jeopardize the security of the test or examination. Nothing contained in
this subdivision shall prohibit the release of test scores or results as
provided by law, or limit access to individual records as provided by law.
However, the subject of such employment tests shall be entitled to review and
inspect all records relative to his performance on such employment tests.
When, in
the reasonable opinion of such public body, any such test or examination no
longer has any potential for future use, and the security of future tests or
examinations will not be jeopardized, the test or examination shall be made
available to the public. However, minimum competency tests administered to
public school children shall be made available to the public contemporaneously
with statewide release of the scores of those taking such tests, but in no
event shall such tests be made available to the public later than six months
after the administration of such tests.
§ 2.2-3705.1 (5): Closed meetings. Provides
an exemption for:
Records
recorded in or compiled exclusively for use in closed meetings lawfully held
pursuant to § 2.2-3711. However, no record that is otherwise open to inspection
under this chapter shall be deemed exempt by virtue of the fact that it has
been reviewed or discussed in a closed meeting.
§ 2.2-3705.1 (6): Vendor
proprietary information. Provides an exemption for:
Vendor
proprietary information software that may be in the public records of a public
body. For the purpose of this subdivision, "vendor proprietary information
software" means computer programs acquired from a vendor for purposes of
processing data for agencies or political subdivisions of the Commonwealth.
§ 2.2-3705.1 (7): Computer
software.
Provides an exemption for:
Computer
software developed by or for a state agency, state-supported institution of
higher education or political subdivision of the Commonwealth.
§ 2.2-3705.1 (8): Cost estimates of
real property. Provides an exemption for:
Appraisals
and cost estimates of real property subject to a proposed purchase, sale or
lease, prior to the completion of such purchase, sale or lease.
§ 2.2-3705.1 (10): Certain personal
contact information. Provides an exemption for:
Personal
contact information furnished to a public body or any of its members for the
purpose of receiving electronic communications from the public body or any of
its members, unless the recipient of such electronic communications indicates his
approval for the public body to disclose such information. However, access
shall not be denied to the person who is the subject of the record. As used in
this subdivision, "personal contact information" means the
information provided to the public body or any of its members for the purpose
of receiving electronic communications from the public body or any of its
members and includes home or business (i) address, (ii) email address, or (iii)
telephone number or comparable number assigned to any other electronic
communication device.
§ 2.2-3705.1 (12): Contracts. Provides
an exemption for:
Information
relating to the negotiation and award of a specific contract where competition
or bargaining is involved and where the release of such information would adversely
affect the bargaining position or negotiating strategy of the public body. Such
information shall not be withheld after the public body has made a decision to
award or not to award the contract. In the case of procurement transactions
conducted pursuant to the Virginia Public Procurement Act (§ 2.2-4300 et seq.),
the provisions of this subdivision shall not apply, and any release of
information relating to such transactions shall be governed by the Virginia
Public Procurement Act.
§ 2.2-3705.1 (13): Account numbers. Provides
an exemption for:
Account
numbers or routing information for any credit card, debit card, or other
account with a financial institution of any person or public body. However,
access shall not be denied to the person who is the subject of the information.
For the purposes of this subdivision, "financial institution" means
any organization authorized to do business under state or federal laws relating
to financial institutions, including, without limitation, banks and trust
companies, savings banks, savings and loan companies or associations, and
credit unions.
§ 2.2-3705.2 (2): Security systems. Provides
an exemption for:
Documentation
or other information that describes the design, function, operation, or access
control features of any security system, whether manual or automated, which is
used to control access to or use of any automated data processing or
telecommunications system.
§ 2.2-3705.2 (14): Public safety;
critical infrastructure, surveillance, etc. Provides
an exemption for:
Information
contained in (i) engineering, architectural, or construction drawings; (ii)
operational, procedural, tactical planning, or training manuals; (iii) staff
meeting minutes; or (iv) other records that reveal any of the following, the
disclosure of which would jeopardize the safety or security of any person;
governmental facility, building, or structure or persons using such facility,
building, or structure; or public or private commercial office, multifamily
residential, or retail building or its occupants:
a. Critical infrastructure information or
the location or operation of security equipment and systems of any public
building, structure, or information storage facility, including ventilation
systems, fire protection equipment, mandatory building emergency equipment or
systems, elevators, electrical systems, telecommunications equipment and
systems, or utility equipment and systems;
b. Vulnerability assessments, information
not lawfully available to the public regarding specific cybersecurity threats
or vulnerabilities, or security plans and measures of an entity, facility, building
structure, information technology system, or software program;
c. Surveillance techniques, personnel
deployments, alarm or security systems or technologies, or operational or
transportation plans or protocols; or
d. Interconnectivity, network monitoring,
network operation centers, master sites, or systems related to the Statewide
Agencies Radio System (STARS) or any other similar local or regional public
safety communications system.
The same
categories of records of any person or entity submitted to a public body for
the purpose of antiterrorism response planning or cybersecurity planning or
protection may be withheld from disclosure if such person or entity in writing
(a) invokes the protections of this subdivision, (b) identifies with specificity
the records or portions thereof for which protection is sought, and (c) states
with reasonable particularity why the protection of such records from public
disclosure is necessary to meet the objective of antiterrorism, cybersecurity
planning or protection, or critical infrastructure information security and
resilience. Such statement shall be a public record and shall be disclosed upon
request.
Any
public body receiving a request for records excluded under clauses (a) and (b)
of this subdivision 14 shall notify the Secretary of Public Safety and Homeland
Security or his designee of such request and the response made by the public
body in accordance with § 2.2-3704.
Nothing
in this subdivision 14 shall prevent the disclosure of records relating to (1)
the structural or environmental soundness of any such facility, building, or
structure or (2) an inquiry into the performance of such facility, building, or
structure after it has been subjected to fire, explosion, natural disaster, or
other catastrophic event.
As used
in this subdivision, "critical infrastructure information" means the
same as that term is defined in 6 U.S.C. § 671.
§ 2.2-3705.4 (1): Scholastic
records.
Provides an exemption for:
Scholastic
records containing information concerning identifiable individuals, except that
such access shall not be denied to the person who is the subject thereof, or
the parent or legal guardian of the student. However, no student shall have
access to (i) financial records of a parent or guardian or (ii) records of instructional,
supervisory, and administrative personnel and educational personnel ancillary
thereto, that are in the sole possession of the maker thereof and that are not
accessible or revealed to any other person except a substitute.
The
parent or legal guardian of a student may prohibit, by written request, the
release of any individual information regarding that student until the student
reaches the age of 18 years. For scholastic records of students under the age
of 18 years, the right of access may be asserted only by his legal guardian or
parent, including a noncustodial parent, unless such parent's parental rights
have been terminated or a court of competent jurisdiction has restricted or
denied such access. For scholastic records of students who are emancipated or
attending a public institution of higher education in the Commonwealth, the
right of access may be asserted by the student.
Any
person who is the subject of any scholastic record and who is 18 years of age
or older may waive, in writing, the protections afforded by this subdivision.
If the protections are so waived, such records shall be disclosed.
§ 2.2-3705.5 (1): Health. Provides
an exemption for:
Health
records, except that such records may be personally reviewed by the individual
who is the subject of such records, as provided in subsection F of §
32.1-127.1:03.
Where the
person who is the subject of health records is confined in a state or local
correctional facility, the administrator or chief medical officer of such
facility may assert such confined person's right of access to the health
records if the administrator or chief medical officer has reasonable cause to
believe that such confined person has an infectious disease or other medical
condition from which other persons so confined need to be protected. Health
records shall only be reviewed and shall not be copied by such administrator or
chief medical officer. The information in the health records of a person so
confined shall continue to be confidential and shall not be disclosed by the
administrator or chief medical officer of the facility to any person except the
subject or except as provided by law.
Where the
person who is the subject of health records is under the age of 18, his right
of access may be asserted only by his guardian or his parent, including a
noncustodial parent, unless such parent's parental rights have been terminated,
a court of competent jurisdiction has restricted or denied such access, or a
parent has been denied access to the health record in accordance with §
20-124.6. In instances where the person who is the subject thereof is an
emancipated minor, a student in a public institution of higher education, or is
a minor who has consented to his own treatment as authorized by § 16.1-338
or 54.1-2969, the right of access may be asserted by the subject person.
For the
purposes of this chapter, statistical summaries of incidents and statistical
data concerning abuse of individuals receiving services compiled by the
Commissioner of Behavioral Health and Developmental Services shall be
disclosed. No such summaries or data shall include any information that
identifies specific individuals receiving services.
§ 2.2-3705.6 (3): Economic
development and retention. Provides an exemption for:
Proprietary
information, voluntarily provided by private business pursuant to a promise of
confidentiality from a public body, used by the public body for business,
trade, and tourism development or retention; and memoranda, working papers, or
other information related to businesses that are considering locating or
expanding in Virginia, prepared by a public body, where competition or
bargaining is involved and where disclosure of such information would adversely
affect the financial interest of the public body.
§ 2.2-3705.6 (10): Virginia Public
Procurement Act. Provides an exemption for:
Confidential
information designated as provided in subsection F of § 2.2-4342 as trade
secrets or proprietary information by any person in connection with a
procurement transaction or by any person who has submitted to a public body an
application for prequalification to bid on public construction projects in
accordance with subsection B of § 2.2-4317.
§ 2.2-3705.6 (11): Virginia Public-Private
Transportation Act of 1995 and the Public-Private Education Facilities and
Infrastructure Act of 2002. Provides an
exemption for:
a.
Memoranda, staff evaluations, or other information prepared by the responsible
public entity, its staff, outside advisors, or consultants exclusively for the
evaluation and negotiation of proposals filed under the Public-Private
Transportation Act of 1995 (§ 33.2-1800 et seq.) or the Public-Private
Education Facilities and Infrastructure Act of 2002 (§ 56-575.1 et seq.) where
(i) if such information was made public prior to or after the execution of an
interim or a comprehensive agreement, § 33.2-1820 or 56-575.17 notwithstanding,
the financial interest or bargaining position of the public entity would be
adversely affected and (ii) the basis for the determination required in clause
(i) is documented in writing by the responsible public entity; and
b.
Information provided by a private entity to a responsible public entity,
affected jurisdiction, or affected local jurisdiction pursuant to the
provisions of the Public-Private Transportation Act of 1995 (§ 33.2-1800
et seq.) or the Public-Private Education Facilities and Infrastructure Act of
2002 (§ 56-575.1 et seq.) if disclosure of such information would reveal (i)
trade secrets of the private entity; (ii) financial information of the private
entity, including balance sheets and financial statements, that are not
generally available to the public through regulatory disclosure or otherwise;
or (iii) other information submitted by the private entity where if such
information was made public prior to the execution of an interim agreement or a
comprehensive agreement, the financial interest or bargaining position of the
public or private entity would be adversely affected. In order for the
information specified in clauses (i), (ii), and (iii) to be excluded from the
provisions of this chapter, the private entity shall make a written request to
the responsible public entity:
(1) Invoking such exclusion upon
submission of the data or other materials for which protection from disclosure
is sought;
(2) Identifying with specificity the data
or other materials for which protection is sought; and
(3) Stating the reasons why protection is
necessary.
The
responsible public entity shall determine whether the requested exclusion from
disclosure is necessary to protect the trade secrets or financial information
of the private entity. To protect other information submitted by the private
entity from disclosure, the responsible public entity shall determine whether
public disclosure prior to the execution of an interim agreement or a
comprehensive agreement would adversely affect the financial interest or
bargaining position of the public or private entity. The responsible public
entity shall make a written determination of the nature and scope of the
protection to be afforded by the responsible public entity under this
subdivision. Once a written determination is made by the responsible public
entity, the information afforded protection under this subdivision shall
continue to be protected from disclosure when in the possession of any affected
jurisdiction or affected local jurisdiction.
Except as
specifically provided in subdivision 11 a, nothing in this subdivision shall be
construed to authorize the withholding of (a) procurement records as required
by § 33.2-1820 or 56-575.17; (b) information concerning the terms and
conditions of any interim or comprehensive agreement, service contract, lease,
partnership, or any agreement of any kind entered into by the responsible
public entity and the private entity; (c) information concerning the terms and
conditions of any financing arrangement that involves the use of any public
funds; or (d) information concerning the performance of any private entity
developing or operating a qualifying transportation facility or a qualifying
project.
For the
purposes of this subdivision, the terms "affected jurisdiction," "affected
local jurisdiction," "comprehensive agreement," "interim
agreement," "qualifying project," "qualifying
transportation facility," "responsible public entity," and "private
entity" shall mean the same as those terms are defined in the
Public-Private Transportation Act of 1995 (§ 33.2-1800 et seq.) or in the
Public-Private Education Facilities and Infrastructure Act of 2002 (§ 56-575.1
et seq.).
Virginia Freedom
of Information Advisory Council
Contact
Information
Alan Gernhardt
Executive
Director
Joseph Underwood
Senior Attorney
General
Assembly Building
201 North
9th Street
Richmond, VA 23219
Telephone:
(804) 698-1810
Toll-Free:
1-866-448-4100
Email: foiacouncil@dls.virginia.gov
Website: http://foiacouncil.dls.virginia.gov
Advisory
opinions of the FOIA Council are available on the FOIA Council website.
[1] FOIA Council Opinions AO-3-00, AO-05-09. All FOIA opinions are available on the FOIA Council's website.
[2] FOIA Council Opinion AO-07-11.
[3] FOIA Council Opinions AO-18-04, AO-07-11.
[4] FOIA Council Opinions AO-07-11, AO-05-18.
[5] FOIA Council Opinions AO-34-01, AO-47-01, AO-05-06, AO-02-08, AO-07-08, AO-07-11, AO-06-14, AO-01-17.
[6] FOIA Council Opinions AO-10-02, AO-12-03, AO-18-03, AO-01-08, AO-07-08, AO-01-17.
[7] Prior to July 1, 2007, FOIA permitted four responses to a records request; see FOIA Council Opinions AO-1-00, AO-21-01, AO-12-03, AO-18-03, AO-16-04, AO-05-05, AO-05-06, AO-11-07, AO-12-07, AO-03-08, AO-07-08, AO-13-08, AO-01-09, AO-07-11, AO-02-12, AO-01-17.
[8] FOIA Council Opinions AO-11-00, AO-6-01, AO-11-01, AO-35-01, AO-49-01, AO-01-02, AO-03-02, AO-10-02, AO-11-03, AO-04-04, AO-10-04, AO-16-04, AO-05-05, AO-06-05, AO-09-07, AO-11-07, AO-07-08, AO-12-09, AO-07-11, AO-04-15.
[9] FOIA Council Opinions AO-1-00, AO-21-01, AO-25-01, AO-32-01, AO-39-01, AO-49-01, AO-05-02, AO-10-02, AO-14-02, AO-08-03, AO-20-03, AO-21-03, AO-01-04, AO-04-04, AO-16-04, AO-23-04, AO-06-05, AO-02-07, AO-09-07, AO-06-09, AO-07-11, AO-03-12, AO-05-13, AO-02-14, AO-04-15.
[10] FOIA Council
Opinions AO-21-01, AO-14-02, AO-04-04, AO-16-04, AO-08-09, AO-07-11.
[11] FOIA Council Opinions AO-11-00, AO-10-02, AO-11-02, AO-14-02, AO-21-03, AO-05-05, AO-08-09, AO-05-13.