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STATE OF NEW YORK
DEPARTMENT OF STATE
COMMITTEE ON OPEN GOVERNMENT
Committee Members
Laura L. An glin
Tedra L. Cobb
Lorraine A Cones-Vazquez
John C. Egan
Michelle K. Rea, Chair
Clifford Richner
Executive Director
Roben J Freeman
Mr. Albert P. Roberts
Vergilis, Stenger, Roberts & Davis, LLP
1136 Route 9
Wappingers Falls, NY 12590
Dear Mr. Roberts:
I have received your letter of September 23.
One Commerce Plaza, 99 Washington Ave., Suite650, Albany, New York 12231
(518)474-2518
Fax (518) 474-1927
Website Address: hnp:l /www.dos.state.ny.us/coog/coogwww.html
December 19,2008
The attached material may offer clarification concermng the Issue raised In your
correspondence.
BY:
JMM:RJF:jm
Ene.
Sincerely,
ROBERT J. FREEMAN
Executive Director
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I anet M. Mercer
Administrative Professional
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,- oft 2Q 2008
. Welcome to the Committee on Open Government
Page lof3
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Department of State
DOS Homepage I Corporations I Licensing I Local Government I Fire Prevention & Control I Commissions
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Committee'on Open Government
Freedom of
Information Law
F@IL
New Provisions Modernize and Clarify FOIL
Legislation approved by Governor Paterson and effective August 7.2008 (Chapter 223) modernizes
the Freedom of Information Law (FOIL) and clarifies several of its provisions The amendments
reflect a recognition of advances in information technology. as well as judicial determinations and
advisory opinions prepared by the Committee on Open Government. It also provides guidance to
agencies and the public concerning the costs associated with providing access to information that is
maintained electronically.
Fees for Electronic Information
Large Requests
Recognizing the Benefits of Information Technology
Creating, Extracting and Generating Records
New Provisions Concerning Privacy
Maximizing Access to Records
Real Property Records
County Clerks' Fees
New Provisions Modernize and Clarify FOIL
Legislation approved by Governor Paterson and effective August 7.2008 (Chapter 223) modernizes
the Freedom of Information Law (FOIL) and clarifies several of its provisions. The amendments
reflect a recognition of advances in information technology, as well as judicial determinations and
advisory opinions prepared by the Committee on Open Government. It also provides guidance to
agencies and the public concerning the costs associated with providing access to information that is
maintained electronically.
Fees for Electronic Information
A new section 87(1 )(e) for the first time defines the basis for determining the actual cost of
reproducing records maintained electronically. For many years. section 87(1 )(b)(iii) of FOIL stated
that unless a different fee is prescribed by statute, an agency could charge a maximum of twenty-
five cents per photocopy when records are made available. or the actual cost of reproducing other
records. i.e.. those that are not or cannot be photocopied. The new provisions balance the public
interest in gaining access to computerized records at low cost with the tasks carried out by agencies
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12/4/2008
Welcome to the Committee on Open Government
Page 2 of 3
when making those records available.
In most instances, gaining access to those records can be realized without a financial hardship, for
the actual cost relating to most requests involves only the cost of the storage medium in which the
information is made available. i.e., a computer tape or disk. However, in those instances in which
substantial time is needed to prepare a copy, at least two hours of an employee's time. the
legislation permits an agency to now charge a fee based on the cost of the storage medium used, as
well the hourly salary of the lowest paid employee who has the skill needed to do so. This change in
FOIL for the first time authorizes agencies to determine and assess a fee to be charged on the basis
of an employee's time.
In rare cases, those in which an agency's information technology equipment is incapable of
preparing a copy. an agency can charge the actual cost of engaging a private professional service to
do so. In analogous circumstances, it has been advised that a fee based on actual cost may Include
all expenditures incurred by an agency associated with preparing a copy. such as postage,
tr;lnsrorl;:llion and the like. Expenditures of that nature may. in our view, be included as part of the
actual cost and the fee that an agency could charge. An applicant must be informed of the tee In
advance if more than two hours of employee time or an outside professional service is needed to
prepare a copy of a record. With advance knowledge of the amount of the fee that would be
assessed, applicants in many situations may narrow the scope of their requests.
Large Requests
The initial clause of amendments to section 89(3)(a) of FOIL codifies and confirms the judicial
finding that a denial of access to records due to a contention that an agency has a shortage of staff
would. in the words of that decision, "thwart the very purpose of the Freedom of Information Law and
make possible the circumvention of the public policy embodied in the Act" [United Federation of
IilJ~~J!~[$I!..N.~w.YQr.kj::;ltyHeallhangJiQ$pltal!t~QIP-"Iati9n. 428 NYS2d 823. 824 (1980)]. The
ensuing clause states that an agency cannot deny a request due to insufficient staff or other basis if
an outside service can be retained to accommodate the applicant. and if the applicant agrees to pay
the actual cost of reproducing the records.
Recognizing the Benefits of Information Technology
A new section 87(5) requires an agency to "provide records on the medium requested...if the agency
can reasonably make such copy." This requirement clarifies and confirms judicial decisions rendered
over the course of years. those requiring that agencies make records available economically on
computer tapes or disks. rather than photocopying [see Sf:iks~llY-'L.~!JeIQ~. 436 NYS2d 558
(1981)]. or by transferring data onto computer tapes or disks. instead of printing out as much as a
million pages on paper at a cost of thousands of dollars [see Brownstone Publishers. Inc. v. New
YgJ!S.QityJ2~Rartme.n.tQ1J3!Jjl.djD9-S~ 560 NYS2d 642 (1990)]. It also specifies that records provided in
a computer format shall not be encrypted
Creating, Extracting and Generating Records
Section 89(3) of FOIL has long essentially provided that FOIL pertains to existing records and does
not require thai an agency creaie a record in response to a request. However, with advances In
information technology. courts have held that when portions of records, i.e.. databases. can be
extracted or generated from existing records with reasonable effort. an agency is required to do so.
Amendments to that provision now include that requirement in the law itself. The new provision also
states that "Any programming necessary to retrieve a record maintained in a computer storage
system and to transfer that record to the medium requested...or to allow the transferred record to be
read or printed shall not be deemed to be the preparation or creation of a new record." Therefore, if
a request reasonably describes records or data maintained electronically. and when extracting the
data with new programming is more efficient than engaging In manual retrieval or redactions from
non-electronic records, the agency is required to do so.
New Provisions Concerning Privacy
Section 89(2)(b) includes examples of instances in which records or portions of records may be
withheld on the ground that disclosure would constitute "an unwarranted invasion of personal
privacy." Subparagraph (iil) of that provision stated since 1978 that an unwarranted invasion of
personal privacy included "sale or release of lists of names and addresses if such lists would be
used for commercial or fund-raising purposes," The amendment provides that such lists may be
withheld when used for "solicitallon" or fund-raiSing purposes. The substitution of "solicitation" for
"commercial" clarifies the intent of the provision since its enactment, to give state and local
government agencies the authority to preclude the IJse of a IlsI of persons' names and residence
http://www.dos.state.ny.us/coog/foi lnews:2htm I
12/4/2008
. Welc'ome to the Committee on Open Government
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addresses when the list would be used to contact citizens directly in their homes in an effort to solicit
their business. In addition, when a list of names and addresses IS sought, an agency may require
the applicant for such a list to "provide a written certification" that the list will not be used or made
available to any other person for the purpose of engaging in solicitation or fund-raising.
Maximizing Access to Records
Amendments to sections 87 and 89 require an agency to consider public access when contracting
with outside vendors and when designing electronic information systems.
The amendment to section 87 prohibits an agency from entering into or renewing a contract for the
creation or maintenance of records if a contract would impair public inspection or copying.
The amendment to section 89 requires, "whenever practicable and reasonable" that an agency
design its information systems in a manner that permits segregation and retrieval of publicly
available data "in order to provide maximum public access." This amendment does not require an
agency to expend public moneys to alter current practices or procedures. Rather, when agencies
determine to change or purchase new electronic information systems, they are required to consider
access to information within the systems and the protection of privacy, to ensure easy access to
portions of records that are available to the public while guaranteeing the security of other portions
that may properly be withheld. This provision is effective immediately (Chapter 351).
Real Property Records
A new subparagraph (iv) added to section 89(2)(c) specifies that disclosure of records involving real
property, such as assessment records critical to enable individuals to ascertain the fairness of their
real property tax assessment, would not constitute an unwarranted invasion of personal privacy if
disclosed. Those records have historically been accessible to the public pursuant to the Real
Property Tax Law, as well as FOIL. A recent judicial decision appeared to limit disclosure and
created confusion and difficulties in gaining access [CaMPS Inc. v Town of Islip, 822 NYS2d 768
(2006)]. The amendment ends the confusion and guarantees public rights of access.
County Clerks' Fees
Various provisions in the Civil Practice Law and Rules (CPLR) deal with the fees that county clerks
may charge for services that they provide. Section 8019 deals with the preparation of copies, but
referred only to copies made on paper. A new paragraph (5) added to section 8019(f) states that the
provisions in FOIL dealing with the actual cost of reproducing records "in a medium other than
paper" serve as the standard under which county clerks may assess fees for preparing copies of
records.
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12/4/2008
Welcome to the Committee on Open Government
rage J UJ 1
"lEW YORK STATE
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Department of State
DOS 'Homepage I Corporations I Licensing I Local Government I Fire Prevention & Control I Commissions
Committee on Open Government
8Ml
Award of Attorney's Fees under the Open Meetings Law
An amendment to 3107(1) of the Open Meetings Law recently approved is intended to improve
compliance and to ensure that public business is discussed in public as required by that law,
Effective August 5. 2008, the new provision states that when it is found by a court that a public body
voted in private "in material violation" of the law "or that substantial deliberations occurred in private"
that should have occurred in public, the court "shall award costs and reasonable attorney's fees" to
the person or entity that initiated the lawsuit.
The mandatory award of attorney's fees would apply only when secrecy is the issue. In other
instances, those in which the matter involves compliance with other aspects of the Open Meetings
Law, such as a failure to fully comply with notice requirements, the sufficiency of a motion for entry
into executive session, or the preparation of minutes in a timely manner, the award of attorney's fees
by a court would remain. as it has since 1977. discretionary.
The intent of the amendment is not to encourage litigation. On the contrary, it is intended to enhance
compliance and to encourage members of public bodies and those who serve them to be more
knowledgeable regarding their duty to abide by the Open Meetings Law.
http://ww\v.dos.state.ny.us/coog/attorneyfees.html
12/4/2008