FOIL’S SUBJECT MATTER LIST REQUIREMENT:
ARE AGENCIES COMPLYING?
Committee on Oversight,
Analysis and Investigation
Ruben Diaz, Jr.
The research and writing of this report spanned several years with a number of different Committee Chairs and staff people involved. Their efforts should be noted, for without their assistance this final document would not have been completed.
This project began while Assemblyman Jeff Klein was the Oversight Committee Chair and Assemblyman Brian McLaughlin was the Assembly Chair of the Administrative Regulations Review Commission.
Two Assembly staff suggested this review and were the driving force behind its completion: Andrea Zaretzki, with the Oversight Committee and Rich Murphy, with the Administrative Regulations Review Commission. While their involvement remained steady throughout the life of the project, the primary information gathering was done by the Assembly Information Center, which formally requested the information from the state agencies.
The initial compilation of the data was conducted by Kate Lago and Delva Daley and more detailed data analysis and compilation into charts and tables was done by Kathleen Fazio.
The drafting of the final report was done by Rich Murphy, with editing throughout by Kathleen Fazio and Andrea Zaretzki.
Support for the final product and the report recommendations was consistently provided by Assemblymember James Brennan, current Chair of the Assembly Oversight, Analysis and Investigation Committee, and Ruben Diaz, Jr., current Assembly Chair of the Administrative Regulations Review Commission.
TABLE OF CONTENTS
To assist the public in obtaining agency records, FOIL requires agencies to maintain a reasonably detailed current list by subject matter of all records in the possession of the agency, whether or not available under FOIL. Such a list aids those interested in requesting records by identifying what kinds of records are maintained by an agency.
The Chair of the Assembly Committee on Oversight, Analysis and Investigation and the Assembly Chair of the Administrative Regulations Review Commission examined state agency compliance with this provision. The project involved obtaining and reviewing subject matter lists from state agencies in late 2001 through 2004, and meeting with key staff of the Committee on Open Government (COG) and the State Archives and Records Administration (SARA) to obtain information on the requirements for subject matter lists.
Key findings include:
"Knowledge is power."
The axiom that knowledge is power remains as true today as it was centuries ago. Clearly, recent events have shown that some information kept by government agencies is sensitive and access to that information should be carefully regulated. However, as a society we still believe that government belongs to the people, and consequently that most government records should be available to the public. A government that is visible and open to the public enables greater participation in and understanding of the decision-making process, and effective and meaningful public scrutiny helps to keep government accountable.
The Freedom of Information Law (FOIL) was enacted in 1977 to ensure the public has access to the records kept by government.1 Under FOIL, all records of a state or local agency are presumed to be available for public inspection and copying unless they fall within one of the categories specifically exempted from mandatory disclosure. Even records containing personal information are to be made available after entries that might identify an individual are deleted.
The public continues to insist that government agencies must operate in an open and accountable manner. Earlier this year, the Assembly passed legislation (A.6714/Destito) to address concerns that some agencies were using loopholes in the law to ignore and stall responses to public requests for records under FOIL. The legislation requires an agency to either provide records within 20 business days after acknowledging receipt of the request, to specify in writing the date on which the records will be made available and the reasons for the delay. The Senate followed the Assembly's lead and also passed this bill, which was signed by the Governor as Chapter 22 of the Laws of 2005.
To assist the public in obtaining agency records, FOIL requires agencies to adopt regulations indicating the times and places such records are available and the persons from whom the records can be obtained. Every agency must also "maintain a reasonably detailed current list by subject matter, of all records in the possession of the agency, whether or not available" under FOIL.2 Such a list assists the public in identifying what kinds of records are maintained by an agency.
The subject matter list serves the same purpose as a store directory in a supermarket. Shoppers don't walk in expecting to see a sign telling them where to find the Macintosh apples or the chicken noodle soup, but do expect a sign directing them to the produce section or the soup aisle to make it easier to locate the products they want. In the same vein, the Department of Motor Vehicles is not expected to list every record concerning every licensed repair shop, but it does help to know that the DMV subject matter list includes entries for the "business address," "facility number" and "investigation findings" for the repair shops it regulates.
FOIL also established an oversight panel, the Committee on Open Government (COG), to advise state and local agencies and the public on records access issues and to adopt regulations setting minimum standards for agency implementation of FOIL. The rules of COG provide some additional guidance to agencies on how to maintain a "reasonably detailed" and "current" subject matter list. The list "shall be sufficiently detailed to permit identification of the category of record sought," "shall be updated not less than twice per year" and "the most recent update shall appear on the first page of the subject matter list."3 These rules also require each agency to designate one or more records access officers, whose responsibilities include ensuring that agency personnel "maintain an up-to-date subject matter list."4 However, COG has no power to force an agency to comply with FOIL or its rules.
In 2001, the Department of Economic Development (DED) proposed amendments to its FOIL rules to repeal a requirement to update its subject matter list at least twice per year. DED argued that updating the list semi-annually was an "unnecessary administrative requirement" that was "of no real benefit to the public."5 The Assembly Chair of the Administrative Regulations Review Commission and Chair of the Assembly Committee on Economic Development, Job Creation, Commerce and Industry registered objections with DED. They pointed out that the proposed rule was impermissibly inconsistent with the rules of COG, and urged its withdrawal.
DED withdrew the proposed rule change in October 2001. However, in doing so it complained that the "six-month rule" for updating subject matter lists was "unnecessary, burdensome and overkill," and that the "FOIL statutory language is more than enough to ensure that an agency will not allow its subject matter list to become outdated."6
To review actual state agency compliance with the requirements of FOIL and COG rules relating to the subject matter list, the Chair of the Assembly Committee on Oversight, Analysis and Investigation and the Assembly Chair of the Administrative Regulations Review Commission requested an examination of state agency practices in this area. The project involved obtaining and reviewing subject matter lists during 2001-02 and again in 2004.
Initial requests were sent out to 59 state agencies in late 2001 seeking subject matter lists, and several second and third requests were also sent.7 Forty-nine agencies responded in 2001, with 47 agencies submitting a list and two agencies declaring that they no longer maintained a subject matter list. In 2004, 36 agencies responded to a follow-up request, 35 of which provided a list. One agency again stated it no longer maintains a list. During this period meetings were also held with key staff of COG and the State Archives and Records Administration to obtain information on the requirements for subject matter lists and on state records management policies.
The following report documents the findings of the Assembly examination and makes several legislative recommendations for improvements.
1. Public Officers Law (POL), Article 6 (§§84-90).
2. POL §87(3)(c).
3. 21 NYCRR §1401.6(b) & (c).
4. 21 NYCRR §1401.2(b).
5. New York State Register, Vol. XXIII, Issue 38, I.D. #EDV-38-01-00003-P.
6. Letter, Robert J. Beshaw, DED, to Administrative Regulations Review Commission et al., October 11, 2001.
7. See Appendix A for the list of agencies.
Broad noncompliance was found with subject matter list requirements. Most agencies failed to meet the legal standards that an agency must meet - that is, to maintain a list that is both "reasonably detailed" and "current." Agency lapses in compliance included outdated lists and undated lists, lists with little detail or little relation to the "subject matter" in agency records, and outright failure to maintain any list.
State agencies are required to update their subject matter lists not less than twice a year, with the date of the most recent update appearing on the first page of the list. As detailed in Chart A, of the 49 agencies that responded in 2001-02, 75% did not comply with subject matter list rules.8
The agencies were contacted again in 2004 and requested to send the most recent update of their subject matter lists. The results are listed in Chart B. Under COG regulations, every agency should have prepared several semi-annual updates between 2001-02 and 2004.
However, only 10 (27.8%) of those 36 responding agencies provided lists that were updated within the prior six months. Six agencies (16.7%) referred to the lists they had provided in 2001-02 as their most recent versions. For example, the Department of Civil Service responded they were too busy to update their previous list, and that the list they initially submitted in 2001 should be used. Five of these six 2001 lists had been submitted without any date, bringing the total number of undated lists "sent" in 2004 to 17 (47%). One agency responded that it did not maintain a list.
While the legal standards provide an objective standard to assess the timeliness of subject matter list updates, the statutory standard that a list be "reasonably detailed" is somewhat more subjective. Moreover, it would be difficult to prove or disprove the degree of compliance without comparing the categories listed with the actual records in an agency's possession. However, a review of the lists provided by agencies does demonstrate reasons for concern with the degree of detail in many cases.
Samples from select subject matter lists are set forth in Appendix B. These include examples of lists that provide little detail and those that list categories of records in substantial detail, as well as examples of lists derived from records retention schedules.
(I) Some agencies do not even try to maintain a subject matter list
The most basic of FOIL's requirements regarding subject matter lists is that each agency must have one. Therefore, it is troubling that some agencies do not comply with even this basic requirement.
In response to a request for its current subject matter list, the State Insurance Department wrote: "We no longer maintain that record. However, you can find the pertinent information in the General Retention and Disposition Schedule for New York State Government Records. You can obtain a copy of same by writing to. . .State Archives and Record Administration. . . ." (The letter is reproduced in Appendix C.)
As discussed further in the following section on "Using SARA Schedules as Subject Matter Lists," the sole use of the General Retention and Disposition Schedule is inappropriate, as many important records in an agency's possession would be omitted from its subject matter list. Beyond this, neither the law nor COG's regulations permit an agency to abdicate its responsibility to maintain an up-to-date subject matter list. It is unconscionable to tell a member of the public in the Insurance Department's headquarters in Manhattan that he or she must go to the State Archives in Albany to see a list of the categories of records possessed by the Insurance Department - and then return to the Manhattan headquarters to request them.
As FOIL is structured, an agency adopts and operates under its own rules and regulations, which must conform to the regulations adopted by COG. The Insurance Department's regulations provide that a "current list, detailed by subject matter, of all records in the possession of the department shall be available for public inspection and copying" in both its Albany and New York City offices.9 Therefore, the Insurance Department's referral of those seeking its subject matter list to the State Archives constitutes an admission that it is not only out of compliance with FOIL, but with its own regulations as well.10
In a similar vein, the Division of Parole replied simply: ". . .[p]lease be advised that Division of Parole does not currently maintain a subject matter list." (See Appendix C.) Again, this lapse not only violates the explicit requirements of FOIL, but also runs afoul of the Division's own regulations at 9 NYCRR §8008.4, which provide:
"§8008.4 Subject matter list. (a) "Every central office director and unit supervisor; every senior parole officer, or parole officer in charge, of an institution; and every director and area supervisor of a parole area office shall be a custodian of records pursuant to this Part. Every custodian of records shall maintain an up-to-date subject matter list, reasonably detailed, of all records emanating from the custodian or the office represented. (b) The records access officer shall maintain a master list of all records maintained by the division. The master list shall be comprised of the subject matter lists kept by all custodians of records."
The section goes on to require that the lists be sufficiently detailed to permit identification of the record, be updated not less than twice per year, and be made available for inspection and copying.
It should be noted that several other agencies have failed to respond to repeated requests for a copy of their subject matter lists.11 It is therefore possible that there are more than two agencies that do not attempt to maintain a list. What is clear is that there is currently no effective monitoring to ensure that an agency remains in even minimal compliance with FOIL. Additional oversight appears to be needed.
(II) Many subject matter lists are years out of date
The regulatory requirement to update the subject matter list at least twice a year is meant to ensure that a list will help identify all of the records kept by the agency, both current and historical. Of the 49 agencies responding in 2001-02, 12 agencies (24.5%) provided lists that had been updated within the last six months. Another five agencies (10%) provided lists that were out of date by five years or more. Of the 36 agency lists returned in 2004, 10 (27.8%) had been updated within the past six months, and another 8 (22%) were one year or more out of date.
The Thruway Authority's list holds the record for being the most out of date (of those lists that include dates). Their list, submitted in November of 2001, was dated March 1988 - a span of 13½ years. The list clearly omitted major categories of records maintained by the Authority in 2001. For example, even though the Authority assumed jurisdiction over the NYS Canal Corporation in the early 1990's (the cover letter transmitting the list included both the Thruway Authority and Canal Corporation on the letterhead), no categories of records relating to the operations of the Canal Corporation were included in the 1988 list.
In March 2004, the Authority provided a list that added 13 pages of Canal Corporation records as well as five pages of records required by Federal rules. The remainder of the list was the same 36-page list from March 1988 - no other changes in the operations of the Authority in the last 16 years were reflected in its "current" list. For example, since that time the Authority has initiated use of the automated toll collection system known as "E-Z Pass," which has given rise to substantial public and legislative concerns over issues such as billing practices and the information on personal travel maintained by the Authority. However, the Authority's subject matter list provides no inkling that they maintain any types of records relating to E-Z Pass.
Another agency with a severely outdated list is the Department of Labor. Its list consists of 10 individually dated pages. Eight of the pages are dated 06/01/92, while one is dated 05/01/90 and one is dated 08/01/92. The list shows evidence that the agency formerly updated its list every few years, at least in the late 1980's and early 1990's. However, the list submitted in 2001 was over 9 years old, and it was missing significant categories of records. In the Welfare Reform Act of 1997, the Legislature transferred responsibility for all public assistance employment programs from the Department of Social Services to the Department of Labor.12 Not a single category of records relating to this new responsibility is accounted for in the subject matter list that the Department of Labor considers current.
Other agencies that provided lists in 2001-02 that were more than five years out of date include the Banking Department, the Governor's Office of Employee Relations and the Office of Mental Retardation & Developmental Disabilities.
It is possible that even older lists may be kept by some of the agencies that responded with undated lists or by those that did not respond. The evidence clearly indicates that neither the statutory language nor the requirements of COG regulations have been sufficient to ensure that all agencies maintain subject matter lists that are reasonably current by any standard.
(III) Many Agencies Failed to Report the Date of the List as Required
The majority of responding agencies failed to include any date on their subject matter list, making it impossible to ascertain when such lists were last updated. In the 2001-02 round of submissions, 23 out of 47 (46.9%) did not indicate the date of the most recent update. In 2004, the numbers were comparable, with 17 out of the 35 submitted lists undated (48.6%). Even some agencies that listed a date were technically out of compliance, listing the date of the last update on the last page, not on the first page as required by COG regulations. In some cases failing to list the compilation date on the first page is a violation of the agency's own regulations as well as those of COG.
(IV) Few Agencies Were in Full Compliance with All Requirements
Several agencies had lists that were considered timely in 2001-02, but failed to update their lists since then. Chart C identifies the extent to which agencies responded with timely lists in both 2001-02 and 2004.
Specific Findings: "Reasonably Detailed" Lists
In addition to the requirement that the subject matter list be maintained as "up-to-date" or "current," both the FOIL law and COG regulations require that the list be "reasonably detailed."
Some of the documents submitted as subject matter lists fail to meet any plausible standard of "reasonable detail." A few examples will make this clearer.15
In 2001 the Office of the Lieutenant Governor submitted a two-page list entitled "2001 Issue Code Book." The submittal consists solely of an alphabetical listing of New York state agencies, with nothing further to indicate what categories of documents the office possesses. There are no general categories such as "employee travel files" or "press releases," "miscellaneous" or "correspondence," as appear in the lists of many other agencies.
It is not clear how the Lieutenant Governor's records access officer - or the public - could use the Code Book listings to assist in accessing documents. Are documents relating to the School Violence Task Force that the Lieutenant Governor chaired filed under the State Education Department, or the State Police? And under which agency would one look for a hard-copy version of the column carried on her website entitled "Afghan Women Look For Better Life After Taliban"? These are records that her office presumably maintains, yet are not identifiable in the subject matter list.
Also in 2001, the Department of State submitted what appeared to be a hastily put together one-page typed document listing 24 areas that are covered by the agency. Most of the listings are one- or two-word entries, such as "local laws," "state emergencies," "hotel/motels" and "designations." Perhaps demonstrating the Department's awareness of how incomplete its efforts are, the list concludes with the entry "major filings - but there are approx 200." One would never know by reading the list that the Department of State's responsibilities included revamping the State's building code or regulating barbers, cosmetologists, real estate agents and cemeteries. The Department of State failed to provide a modified or updated list in 2004.16
Another apparently incomplete list was provided by the New York State Department of Public Service. In response to the 2001 request, the Department provided a list that gave generalized descriptions of broad subject areas. Examples from this list include: "Memoranda," "Informal and Formal Discovery," and "Workpapers and the like." Coincidentally, one entry on this list mentions "a reasonably detailed, current list by subject matter of all records in the possession of the agency." This is an apt description of the subject matter list required by the Public Officers Law, but does not describe the list actually provided by the Department.
In 2002, the New York Power Authority provided a retention schedule-derived list comprised of 23 pages of alphabetical listings of hundreds of its "corporate record types." In 2004, the agency submitted a significantly abridged list that merely sets forth the names of eighteen units or departments of the Authority (e.g., "Law Department", "Performance Planning Division," "Office of the Chairman"). The 2004 list provided no subject headings, nor did it go into further detail as to what types of documents might be maintained under each unit or department.
Specific Findings: Using SARA Schedules as Subject Matter Lists
As previously noted, the State Insurance Department refers people seeking its FOIL subject matter list to the General Retention and Disposition Schedule for state agencies maintained by the State Archives & Records Administration (SARA). Apart from failing to meet legal requirements to maintain its own list and make it available to the public in its offices, the general schedule is a substantially inadequate substitute for a subject matter list.
SARA, a unit within the State Education Department, is responsible for coordinating the records management activities of state agencies. This includes accepting records for storage in the State Records Center or authorizing agencies to dispose of records with no further legal or practical value. Agencies submit proposals for records retention and disposition schedules or plans to SARA, which must review and approve the proposals before the agency may destroy, transfer custody or otherwise dispose of records.17 Agencies also are required under SARA regulations to implement a records management program, including establishment of "a process to prepare and annually review an agency records management plan, including a current inventory of agency records."18
To streamline administration of records retention and disposition, SARA issues general records retention and disposition schedules applicable to records common to some or all agencies. These general schedules are reviewed by the Attorney General and the State Comptroller to ensure that there are no authorizations to destroy records needed for legal or audit purposes. Once an agency elects to adopt and use a general schedule, it does not need to submit proposals for retention and disposition of those records included on the general schedule.19
The SARA general schedule does not include any categories of records unique to any individual state agency, but only lists those kinds of records common to many agencies. Categories of records include those related to fiscal operations ("budget certificates and approvals," "daily journal reports"), telecommunications management ("telecommunications use logs and reports") and affirmative action ("recruitment plans and reports," "outreach program records"). However, there are many items that are not listed in the general schedule which are clearly important to the work of individual agencies, such as school improvement files maintained by the Education Department or records on toxic waste sites at the Department of Environmental Conservation. These records series may be the subject of individual, agency-specific retention schedules which must be approved by SARA.20
Therefore, it would clearly be insufficient to rely only on the general schedule to list the subject matter of all records in an agency's possession. It appears that some agencies, however, that use these schedules as the basis for their subject matter lists may err in a different way. An agency that uses only its agency-specific schedules and fails to account for any records in the general schedule would also be setting forth an incomplete list. For example, the Office for Technology (OFT) submitted copies of its SARA-approved retention schedules for specific records series along with a copy of its authorization to use the general retention schedule - but apparently does not provide the public with a copy of the general schedule or any information on the categories of records (e.g., correspondence, payroll) that are maintained by OFT in accordance with the general schedule.
Even using a combination of general and agency-specific schedules as subject matter lists can pose other problems for the users of such lists. Because the retention schedules are designed to be useful to SARA and agency records management officers, the information may not be presented in a manner useful to a member of the public seeking information on the subject matter of agency files. Again, OFT's submission was not presented as a "list" by subject matter, but rather as 32 individual pages, each containing the title and description of an individual records series along with a dozen other fields containing information not relevant to identifying subject matter (e.g., volume of existing records and estimated annual growth in cubic feet). If it extracted only the title and description fields, OFT could use them to create a more user-friendly list of about 4 to 5 pages. This is what some agencies, such as the Office of Parks, Recreation and Historic Preservation, seem to have done with their lists.
OFT's cover letter cited an advisory opinion issued by COG's Executive Director (#FOIL-AO-8288)21 , contending these schedules may be used as a substitute for subject matter lists. The opinion, however, concerned the FOIL requirements applicable to the Salamanca Industrial Development Agency, a local government agency subject to one of the all-inclusive local records retention schedules.
COG has issued numerous other advisory opinions indicating that local governments may look to retention schedules to form the basis of a subject matter list. But, even in such cases both COG and SARA indicated that, to avoid confusing the public, the schedule should be vetted to remove any categories the specific local government does not actually maintain.
Both COG staff and the staff of SARA have expressed concern over the use of retention schedules as subject matter lists by state agencies. In meetings with Assembly staff, they indicated that the advice that local agencies may use local retention schedules was never intended to extend to state agencies, that state agencies have never been advised that using retention schedules would be acceptable, and that the differences in how the various types of schedules are designed make state agency use inappropriate.
There is a logical connection between the overlapping tasks of creating comprehensive lists of agency records by subject matter and listing records for purposes of retention or disposal. Possibilities for further integration of the SARA schedules and subject matter lists are discussed in the recommendations.
The purpose of this study was to evaluate agency compliance with the statutory and regulatory requirements that each state agency maintain a reasonably detailed and current subject matter list of records in its possession. The Department of Economic Development had suggested that the regulatory requirement that such lists be updated every six months was "overkill," since the "statutory language is more than enough to ensure that an agency will not allow its subject matter list to become outdated."
Regrettably, the statutory language is not even enough to ensure that an agency maintain any list at all. It is true that many agencies were able to produce a reasonably thorough listing of records categories that was either within or close to the six-month timeline. It is also true that too many agency lists were many years out of date and many were so poorly detailed as to be useless to the public. Far from representing overkill, even in combination, the statutory and regulatory language are insufficient to ensure that timely and useful subject matter lists are maintained by state agencies.
The most apparent problem in this area is the lack of effective monitoring and accountability. There is no enforcement authority or other effective means to ensure that agencies fulfill the requirements of the law and regulations. It is unacceptable to allow agencies to choose whether or not they want to comply with any law, but it is particularly troubling at a time when the public is demanding more accountability from government to see agencies flout a basic requirement to provide open access to government records.
At the same time, it should be noted that many agencies appear to be making good faith attempts to put together some kind of subject matter list, but may be unsure how to do so effectively. These agencies could benefit from various aids, including making one or more model subject matter lists available, providing a guide to best practices (as well as practices to be avoided) and offering advice on how to convert the combined agency-specific and general records retention schedules into an appropriate subject matter list.
Greater accountability might result from harnessing the power of the Internet. If an agency is required to keep its most recent subject matter list posted on its website, it will be obvious to all - agency leadership, other government agencies and the public - if the list has not been updated for several years or is seriously deficient in content. The benefits of Internet posting in "keeping agencies honest" would be even greater if each agency's list is also linked to a common site, such as the COG home page.22 This would facilitate comparisons of the lists of various agencies, and would also enhance oversight of whether the lists were timely and reasonably detailed.23
There are some positive aspects to changing the timeline for updating a subject matter list from biennially to once a year. This would coincide with SARA's requirements for annual preparation of an agency records management plan, and may allow non-compliant agencies to better focus their resources on producing a timely and useful list.
However, to ensure that agencies actually meet any relaxed timetable, provisions should be made for greater oversight and accountability. Under current practices, agencies have used lists that are woefully outdated, in some cases by more than a decade. Worse yet, agencies have been allowed with impunity to refuse to provide the public with any subject matter list. Others have been allowed to provide lists so lacking in detail as to be essentially useless.
If the oversight approach outlined above fails to achieve the goals of current and reasonably detailed subject matter lists, another tactic may be needed. SARA already has considerable information on the categories of agency records, and is authorized to seek any additional information it needs regarding agency records.24 If an agency's compliance with the subject matter list requirements is substantially deficient, COG could be empowered to direct the agency to come into full compliance within a reasonable period of time.
If the agency fails to do so, COG could then transfer the responsibility for developing and posting a subject matter list to SARA. To defray any additional costs, SARA would be entitled to have the necessary funding transferred to it from the agency's budget equal to the amount of the annual fixed fees agencies pay to SARA for its records management services. These fees currently range from $2,000 to $20,000, depending on the volume of records in the custody of the agency. It is believed that this approach would provide sufficient incentive for an agency to comply and avoid an actual transfer of responsibility to SARA. However, in the end it would ensure the desired result - a subject matter list that aids the public in locating and requesting agency records that affect them.
Finally, the accessibility of subject matter lists and the overall FOIL process could be further enhanced if the Internet postings of agencies included not only the subject matter list, but also included other information on FOIL. Currently, some agencies provide information on FOIL on their websites, but most do not.25 Additional information useful to the public would include who the agency's records access officers are, their office location and business hours, how to contact them and how to request records, either electronically or in writing. General information on the FOIL process could be provided through the link to the COG website, while any additional provisions unique to a specific agency could be detailed on its site.
In order to improve public access to agency-maintained information, it is recommended that the following legislation be considered:
The wide variation in the lists’ formats and in the degree of detail provided to the public is illustrated by the following sample pages from lists compiled for this study.
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