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May 23, 2020 by Joseph Braude Leave a Comment
A new opportunity has emerged to roll back generations of antisemitic and rejectionist messaging in Arab media, mosques, and schools. It stems from the convergence of interests between Israel and Arab powers, a youthful Arab grassroots trend in favor of a "peace between peoples," and new Israeli and American Jewish capacities to engage Arab public discussions from the outside in. But prospects for change remain severely constrained: In addition to the effects of the Israeli-Palestinian stalemate, the legacy of antisemitic brainwashing endures in many Arab institutions and draws further energy from Iranian and jihadist information operations. Meanwhile, proponents of a positive shift lack coordination, planning, and adequate support. In Reclamation: A Cultural Policy for Arab-Israeli Partnership, Joseph Braude documents the opportunity as well as the obstacles, and then proposes a strategy to accelerate progress. He explains how to engage Arab allies in a coordinated communications reform effort, support independent Arab champions of civil relations with Israel and Jews, expand the "outside-in" capacities, and degrade Iranian and jihadist channels of indoctrination within Continue Reading…
February 13, 2020 by Joseph Braude Leave a Comment
On January 28, 2020, the long-awaited Trump Peace Plan was unrolled in a White House press conference alongside Israeli Prime Minister Binyamin Netanyahu. The Arab Council for Regional Integration responded promptly to the plan in a communique released from Cairo a day later. It was subsequently published in newspapers across North Africa and the Middle East, and appeared in policy institute surveys of Arab responses to the Trump plan. The following is the text of the Arab Council's statement: "The 24 hours since the release of the Trump peace plan yesterday have witnessed an outpouring of emotion on the streets of some of our capitals. On the one hand, the anger conveyed in these demonstrations does not reflect a considered view of the content of the 80-page White House proposal, and questions can and should be raised about the organizers of the demonstrations and their motives. "On the other hand, let no one doubt the genuineness of feeling and energy which protesters have shown. They want Palestinians to achieve their Continue Reading…
December 15, 2017 by Joseph Braude Leave a Comment
Amid civil war, failing states, and terrorism, Arab liberals are growing in numbers and influence. Advocating a culture of equity, tolerance, good governance, and the rule of law, they work through some of the region's largest media outlets to spread their ideals within the culture. Broadcasting Change analyzes this trend by portraying the intersection of media and politics in two Arab countries with seismic impact on the region and beyond. In Saudi Arabia, where hardline clerics silenced their opponents for generations, liberals now dominate the airwaves. Their success in weakening clerics' grip over the public space would not only help develop the country; it would ensure that the birthplace of the prophet Muhammad exports a constructive understanding of Islam. In Egypt, home to a brutal government crackdown on Islamists and a bloodsport of attacks on Coptic Christians, local liberals are acting with courage on the ground and over the airwaves. Through TV talk shows, drama, and comedy, they play off the government's anti-Islamist agenda to more thoughtfully advocate religious reform. Continue Reading…
Trump's ambassador to the UN lays off Doha and pressures Juba. To subscribe to this daily roundup by Mideast specialist Joseph Braude, click here. In a remarkable about-face, Nikki Haley tells Congress that Qatar "does not fund Hamas." … "Haley's reversal, contained in a memo to Congress obtained by BuzzFeed News, comes as Secretary of State Rex Tillerson seeks to unite competing factions in the Trump administration behind a common policy in the high-stakes Gulf crisis." That policy effectively leans in favor of the Qatari position. The position, as described in the article, is to view the four-country blockade as "a threat to both stability in the region and the US air base in Qatar, which is home to the largest concentration of U.S. military personnel in the Middle East." Haley's remarks include the following: "While the Qatari government does not fund Hamas, it does allow Hamas political representatives to be based in Qatar, which Qatar believes limits Iran's influence and pressure over Hamas. … Qatar has committed to take Continue Reading…
Filed Under: Uncategorized Tagged With: Amir Taheri, Donald Trump, Eli Lake, Iran, Iran, JCPOA, Joseph Braude, Joseph Braude, Joseph Braude, Joseph Braude, Joseph Braude, Joseph Braude, Saudi Arabia, Vladimir Putin
Filed Under: Uncategorized Tagged With: Austria, Institute for Near Eastern Studies, Lorenzo Vidino, Muslim Brotherhood, University of Vienna
Filed Under: Uncategorized Tagged With: Alberto Fernandez, Bernard Haykel, Bipartisan Policy Center, Charles Hill, Cheryl Benard, Christopher Kojm, Husain Haqqani, John Gannon, John Jenkins, Kristin Lord, Nibras Kazimi, Sam Tadros, Samuel Tadros, Tarek Elgawhary, Task Force on Countering Terrorism and Ideology, Thomas Kean, Tom Kean
Joseph Braude's New and Noteworthy in Arab and Islamic Affairs, 9-13-17
An Arab League slugfest over Qatar, a shvitzing frenzy in Israel over GCC ties, and Polisario fears of a mass exodus from the Saharan camps. To subscribe to this daily roundup, click here. Acrimony at the Arab League over Qatar: Tensions escalated at the summit in Cairo as Doha FM called Iran an "honorable state" and dubbed rival regimes' media "dogs." Saudi Arabia and the UAE reiterated that their list of 13 demands remained the basis for negotiation over resolving the conflict. Kuwait's deputy FM, sworn to media the intra-GCC feud, hit back at the Qatari praise for Iran: "Despite Kuwait's efforts to open up communication channels for dialogue between Arabian Gulf countries and neighbouring Iran with a view to enhancing regional security and stability, the Islamic Republic has continued its interference in domestic Arab affairs. Meanwhile, Washington remains a battlefield among the Gulf states' hired hands. A shvitzing frenzy in Israel over GCC ties: An Israel radio broadcast claiming an unnamed Saudi prince had visited the Jewish state has become an international story, and Continue Reading…
Filed Under: Uncategorized Tagged With: Arab League, Polisario, Qatar
Venezuelan ruler heads to Algiers, Moroccan opposition prince booted from Tunisia, and a Saudi crackdown on Islamist clerics. To subscribe to this daily Mideast roundup, click here. Rocked by protests and newly sanctioned by the U.S. Government, Venezuelan president Maduro arrives in Algeria. The sanctions barred U.S. banks from the country and isolated the national oil company. Algerian FM says enhancing oil trade will be discussed. The trip should be understood in the context of the following recent statement by Maduro: "[Let's] start selling oil, gas and all other products that Venezuela sells with new currencies, including the Chinese yuan, the Japanese yen, the Russian ruble, the Indian rupee among others." Algeria may well throw him a lifeline. Sidelined Moroccan prince deported from Tunisia: Moulay Hicham, ensconced at Stanford U. and an outspoken critic of King Mohammed VI, was to have given a lecture about the future of the Arab spring then continue east to Qatar for an event at Brookings Doha. But now he's stuck in Paris. Tunisian authorities are keeping tight-lipped. Saudi Continue Reading…
Filed Under: Blog, Blog, Blog, Blog, Blog, Blog, Blog, Blog, Blog, Blog Tagged With: Awad al-Garni, Awad al-Qarni, Maduro, Morocco, Morocco, Moulay Hicham, Salman al-Awdah, Saudi
New and Noteworthy in Arab and Islamic Affairs, 9-10-17
A fuzzy encounter between the U.S. Navy and Iran, an intra-Jewish spat over relations with Qatar, and scrappy decisions in Algiers. To subscribe to this daily roundup, click here. Iran claims it confronted a U.S. Navy vessel and the U.S. issues a denial. Reuters cites Tasnim News Agency as saying an "Iranian military vessel confronted an American warship in the Gulf and warned it to stay away from a damaged Iranian fishing boat." U.S. Naval Central Command acknowledged it heard a small boat's distress call 75 miles away but "at no time was there any direct contact between the U.S. and Iranian maritime forces." Qatar pays a Jewish-owned PR firm to court American Jews, but a Chabad rabbi warns Jews that Doha has blood on its hands. Times of Israel: "Qatar is paying $50,000 a month for outreach to the Jewish community to a prominent Jewish Republican operative at a time when the Persian Gulf nation is facing calls for isolation from other moderate Arabs and by conservatives in Washington, DC." Full page ad in the New Continue Reading…
Filed Under: Uncategorized Tagged With: Algeria, Shmuley Boteach


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TagEconomicsEducation
ContributorAlex BlumbergIra Glass
477: Getting Away With It
Act Four: Pre K-O
Producer Alex Blumberg tells the story of how Oklahoma, against huge odds,came to have the first and best publicly-funded pre-school system in thecountry, and how one businessman joined the fight because a cardboard boxfull of evidence convinced him that pre-school was the smartest businessdecision the state could make.
475: Send a Message
Act Three: Soul Sister
Sonari Glinton tells the story of how a Catholic nun teaches an entire school on Chicago's South Side that we are all truly made in God's image. Sonari is a reporter for NPR News.
474: Back to School
Host Ira Glass talks about his experiences reporting on education and theunending question of how we can make schools better. He discusses theChicago Teachers strike and an essay by writer Alex Kotlowitz that talksabout how the strike raises questions about the severity of this challenge.
Our story picks back up with the question of how non-cognitive skills can be taught to older kids who have gone much longer without learning things like self-control, conscientiousness and resilience. Ira returns to the story of Kewauna, the Chicago teenager, who talks about the dramatic ways in which she changed her life.

redpajama_set_name: RedPajamaCommonCrawl


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As an Australian company, Blackmores adheres to the some of the most rigorous safety and quality standards in the world. Unlike many other countries, Australia regulates complementary medicines within the same legal framework as pharmaceutical drugs.
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In 2018 Blackmores invested in more than 74 clinical trials, research projects and scholarly activities in partnership with some of the best educational and research institutions across Asia-Pacific.
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Good health is at the heart of everything we do at Blackmores. It's why we exist. Therefore, we take the unlikely event of an adverse reaction to one of our products extremely seriously.
If this happens, we comply with the requirements of the Therapeutic Goods Administration (TGA) and the Australian Competition and Consumer Commission (ACCC) to report the case immediately and take corrective action without delay.


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Chiropractic Websites
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Democracy is being eroded across the world.
Help us defend it through trustworthy, independent journalism.
openDemocracyUK: Analysis
Why the UK's system of government is vastly superior to the European Union
British governments can survive only if they enjoy a majority in the Commons. In the EU, by contrast, executives are appointed by governments
This article summarises the last of three lengthy essays about the European Union by the historian Perry Anderson, published in the London Review of Books.
David Elstein
28 March 2021, 8.00am
A democratic-looking screen
RichardBakerBrexit/Alamy Stock Photo. All rights reserved
Perry Anderson's case against the European Union
How the European Union has always preferred power grabs to democracy
How all-powerful institutions keep Europe in gridlock
Perry Anderson's third essay on the European project, 'The Breakaway', traces the history of the UK's involvement, from non-participant to rejected supplicant to member for 47 years and then to fractious departure.
The UK was an uninterested spectator as six European states formed the European Coal and Steel Community, the 1950s ancestor of the European Union. Neither was it involved when the Treaty of Rome in 1957 created the European Economic Community (EEC), superseding the Coal and Steel Community.
Later, national economic decline and foreign policy upheavals such as the Suez crisis and decolonisation led the two prime ministers named Harold – Macmillan and Wilson – to each seek membership of the Common Market, the European free-trade zone. The French president, Charles de Gaulle, vetoed both bids. Only when Georges Pompidou succeeded de Gaulle did a Conservative prime minister, Edward Heath, manage to break the logjam, joining the six founding member states in the EEC alongside Denmark and Ireland in 1973.
Forty or so of Heath's own MPs opposed joining, but a band of 69 pro-European MPs within the otherwise hostile parliamentary Labour Party outnumbered them, giving Heath a majority of 17 for passage of the European Communities Bill in 1972. Perhaps the narrowness of that margin dissuaded him from fulfilling his pledge not to join the EEC without "the full-hearted consent" of the British people. He rejected the idea of a referendum implied in that formulation and avoided mentioning the inescapable fact that the UK had sacrificed a degree of sovereignty in conceding the supremacy of European law – a condition of EEC membership.
It was Wilson, returned to power, who – says Anderson – "went through the motions of renegotiating the terms secured by Heath" and then in 1975 mounted a referendum. On a turnout of 64%, the majority in favour of Wilson's deal was more than 2:1.
The British pushback
When Margaret Thatcher won the 1979 general election, she launched a campaign to cut the UK's disproportionate contribution to the EEC budget, and managed to recoup two-thirds. The Single European Act of 1987, a major revision of the Treaty of Rome, carried her personal stamp, having been steered through by her nominated commissioner. The country's position in Europe seemed both distinctive and secure.
However, Thatcher – having broken with her Chancellor of the Exchequer, Nigel Lawson, over his attempts to make sterling shadow the EEC's Exchange Rate Mechanism – was determined to resist the drive within Brussels and Frankfurt for the mechanism to be upgraded to a full-blown single currency. This opposition forced the resignation of her foreign secretary, Geoffrey Howe, who in turn lit the fuse that led to her own departure from Downing Street.
Her preferred candidate, John Major, won the succession and negotiated a British opt-out from the euro. But even in doing so, and to the dismay of many of his backbenchers, he signed up to the 1992 Treaty of Maastricht, which created the European Union. The anti-Maastricht Tories, seeing the Danes reject the treaty in a referendum, called for just such a vote at home – supported, as it happens, by the Liberal Democrats. Major's position was fatally undermined when the UK was forced out of the Exchange Rate Mechanism after a run on the pound on 'Black Wednesday' later in 1992.
Under intense pressure from Brussels, Denmark held a second referendum, overturning the first. Major finally persuaded the British parliament to ratify Maastricht even so, but his authority over his own party was broken, and the humiliating exit from the Exchange Rate Mechanism had so tarnished the Tory brand that Tony Blair comfortably won the 1997 election.
Major's three successors as Tory leader, all opponents of Maastricht, all trailed behind Blair in voter preference. Instead, Blair's most formidable opponent proved to be his chancellor, Gordon Brown, whose dogged resistance thwarted all the prime minister's designs to join the single currency.
What Brown had not seen coming when in due course he himself became prime minister in 2007 was the financial crisis the following year. He was duly dislodged in 2010, with the first pro-Europe leader of the Conservatives since Major – David Cameron – heading the largest party within a coalition with the Liberal Democrats, the most ardent pro-Europeans in Parliament.
The road to referendum
However, this victory was shadowed by the previous year's European elections, where the upstart UK Independence Party beat Labour into second place. Pressure from UKIP's electoral successes and from his own malcontents on the back benches was generating a momentum that Cameron thought he could control, but could not.
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The UK's ineffectuality and marginality could not have been more vividly displayed
Legislation requiring a referendum before the UK could agree any further treaty with the European Union passed through Parliament in 2011. Meanwhile, Angela Merkel's determination to push through her precious Fiscal Compact – as protection for the Eurozone from external and internal pressures – undermined Cameron's position.
He vetoed the package in a vote at the December 2011 European Council, which comprises the heads of government of the European Union. But then Merkel sidestepped the council and secured agreement to the proposals in a multilateral inter-governmental treaty outside the scope of the EU. The UK's ineffectuality and marginality could not have been more vividly displayed. In 2013, Cameron pledged an in/out referendum if he won the next election.
The reputation of the Lib Dems had been badly damaged because of policies they had both supported and abandoned to remain in the coalition. The party's vote collapsed in the 2015 election and Cameron found himself with a clear majority, unencumbered by a junior partner that might veto a referendum, and chose to keep his promise, encouraged by his success in facing down a bid for Scottish independence.
The Brexit campaign
Cameron set June 2016 for the poll: but where his own party had remained united on the question of Scotland, on the European Union it was deeply split. UKIP's victory in the 2014 European elections (based on proportional representation) had frightened many Tory MPs, fearful of a direct challenge in a Westminster first-past-the-post poll. One Tory MP resigned, fought the consequent by-election for UKIP, and won.
Scores of backbench Tories created a powerful and disciplined parliamentary party-within-a-party: the European Research Group. But its tactical skills, honed in Westminster, would most likely have had little resonance in a referendum campaign: it was the decision by a swathe of Cameron's cabinet and junior ministers to join the Leave campaign, led by Michael Gove and Boris Johnson (not members of the ERG), which broadened the appeal of Brexit beyond the diehard faction, allowing it to attract a swathe of Labour MPs and voters.
The new Labour leader, Jeremy Corbyn, expressed only lukewarm support for the European Union and kept well away from any pro-EU campaigning alongside Conservatives. As a result, even though 73% of MPs from all parties supported Remain, and it was the official policy of all parties other than UKIP, that support could not fully express itself. Contrast that with the Scottish referendum, in which anti-independence parties joined forces to promote a 'No' vote.
The key issue was control over their own, and the country's, destiny
Perry Anderson
The people, however, thought differently to their MPs. In the event, reports Anderson, "the only socioeconomic group where a majority voted Remain was the most affluent stratum of the population, composed of members of categories A and B". Overall, Leave won 52%, "rising to 64 per cent in the poorest categories of C2DE". Voters under age 24 split 73:27 for Remain; most of those aged over 44 chose Leave. With 81% of those receiving full-time education preferring Remain, "geographically, in England, it was in University towns alone that Remain won handsomely".
Why did Leave win?
For Remainers, says Anderson, there was a sense that leaving the union would be a victory for chauvinism and reaction; and also that it "threatened living standards, which were bound to drop cruelly on exit"; but for the poorest voters, "the key issue was control over their own, and the country's, destiny, something that could only be secured by departure from the EU".
Another motive for supporting Leave was a wider sense of recovering independence, to which, says Anderson, "control of immigration and borders came second".
That said, he continues, immigration did play a part in Leave voters' decisions. One of "two critical legacies of New Labour" was the surge in immigration "derived from Blair's decision in 2004 to reward his Eastern European allies for their staunch role in the Iraq War" by not seeking to limit free movement (as Germany did) when the EU expanded that year.
"Some 700,000 Poles eventually came, many more than Blair had bargained for. No other European country knew an influx of comparable size and speed so early on. By 2017, 400,000 Romanians and Bulgarians had joined them." The Cameron government "could do nothing to halt or mitigate" the influx.
The second legacy – Blair's failure to overrule Brown and join the euro – "was probably more decisive". Once a country is inside the single currency, "fear of the consequences of departure trumps all else if the issue is tested at the polls".
In the eurozone, after all, "people's savings were held in euros. To leave the Monetary Union when this was an established fact was to destroy their value. No party with a popular base dares risk such a prospect." Anderson cites the verdict of the political sociologist Claus Offe: "Though imposition of the single currency was a huge mistake for Europe, unwinding it risks even greater harm for ordinary citizens."
The Leave campaign succeeded because no similar danger was involved. Ironically, in Anderson's view, neither side of the Brexit debate "paid the slightest attention to the obvious fact that (if we exclude toy-states like Liechtenstein, Monaco or Luxembourg) the two richest countries in Europe, with the most advanced welfare systems, do not belong to the EU: Switzerland and Norway. Both societies rejected integration with the Union in popular referendums and have flourished since doing so."
Brexit's difficult gestation
Cameron resigned after the referendum. His successor, Theresa May, seeking to bolster her parliamentary position, called an election in 2017, but despite increasing her party's share of the vote by 5%, lost enough seats to erase her majority in the Commons, becoming dependent on the ten MPs from Northern Ireland's Democratic Unionist Party. Yet the withdrawal agreement she negotiated with Brussels, including a 'backstop' arrangement to ensure no hard border could be imposed between Ireland and the North, wholly alienated the DUP. What's more, several members of her cabinet resigned, including Boris Johnson.
The Labour leadership drifted towards a generic obstructionism in the Commons
With her party badly split, May had no chance of securing a Commons majority for her deal without Labour support: and a fate "worse than disarray", says Anderson, had overtaken Labour, with many of its MPs supporting a second referendum, or 'People's Vote', with no clarity as to whether this meant overturning the first result, or just allowing second thoughts; its promoters were divided as to which they preferred, and the People's Vote organisation eventually fell apart.
"In the background," says Anderson, "under pressure from the PLP, the Guardian, the BBC and its own youth, the Labour leadership drifted towards a generic obstructionism in the Commons."
After her deal had been repeatedly rejected by the Commons, May eventually resigned. Her successor, Johnson, faced resistance in the courts as well as in Parliament as he tried to wriggle free of the trap which had brought her down. He repeatedly called for cross-party agreement to an early election to break the deadlock, but it was only when the Lib Dems, scorning even a second referendum, opted for an election in which they would campaign for rescinding the UK's notice to withdraw from the union, that Labour's hand was forced.
Johnson had defied predictions by securing a withdrawal agreement with the European Union, providing an 11-month standstill during which a long-term treaty could be negotiated. He claimed the agreement solved the 'Irish backstop' issue, but the DUP remained unconvinced. They, however, promptly lost their leverage, as Johnson won a large majority in the December 2019 election, freeing him of reliance on them.
Corbyn duly resigned, and his replacement, Keir Starmer, who had for so long championed a second referendum, now decided that Brexit was done, and nodded through the Commons in just four hours of debate the treaty Johnson finally secured with the European Union in December 2020.
Against Brexit
Anderson cites the standard predictions of a 4% loss of potential UK GDP growth with an agreed exit, as compared with 6% without a deal: "what else could be expected, given the disparity – the European Union being more than six times the size of the UK in output and population – in the bargaining power of the two sides?" But he notes that long-term macro-economic forecasts "are rarely foolproof", and that the EU is anyway far from being a champion of free trade: "It is a mercantilist bloc, replete with subsidies (think only of the Common Agricultural Policy) and protections (think only of services) of many kinds, aimed at barricading outsiders from the privileges afforded to insiders."
[The euro is] the oligarch project to end all oligarch projects
Ferdinand Mount
Anderson addresses three writers on the UK's relationship with the European Union: Ferdinand Mount, Peter Oborne and Geoffrey Wheatcroft. All had connections with or leanings to the Tories in the past but now excoriated the party and its leadership, along with Brexit (Oborne, having voted Leave, lost his nerve during the turmoil of 2019).
Mount had previously identified the fallibility of the union: "an oligarchy [in which] the oligarchs see no reason to alter their practices or their ambitions. No previous empire...carried centralisation so far". As for the euro, it was "the oligarch project to end all oligarch projects". That was written in 2012. More recently, in terms of Brexit, he has not tried "to defend the ramshackle and blatantly imperfect institutions of the EU"; but he is so offended by the person and policies of Boris Johnson ("a seedy, treacherous character"), that he cannot but condemn the Brexiteer sentiment which carried him to power.
Oborne admits that he has no "passion for Remain… only a deep gnawing worry that we are making a significant mistake". Wheatcroft, too, was only a "tepid" Remainer, conscious that the union had enlarged prematurely and then disastrously imposed the euro on southern Europe. His beef was with the referendum itself, as demagogic in nature and misguided in intent; yet he offers no better solution to the question of democratic legitimacy that the European Union had so signally failed to answer.
The EU is the simulacrum of a sentient democracy. For all its woeful shortcomings, Westminster is vastly superior to this lacquered synarchy
Undermining all three critiques, argues Anderson, is the fact that the UK had never been fully committed to the union project: no one on the Remain side of the debate ever argued that it should have joined the eurozone or even the Schengen free-movement zone.
Never the twain
In his view, the key issue is that Westminster and Brussels represent two wholly different types of political structure. Whatever the weaknesses of the British system – anachronistic fogeys as politicians, first-past-the-post elections, an unelected upper chamber, an honours system rewarding bagmen, a Parliament that "can be bundled into a poll at a day's notice" – in Anderson's view "the fact remains that British governments can only survive if they enjoy a majority in the Commons... and if they fall, elections to replace them must ensue.
"In the EU, by contrast, executives are appointed by governments: in practice, it is the simulacrum of a sentient democracy."
For all that it may grate, "and for all its woeful shortcomings... Westminster is vastly superior to this lacquered synarchy". That is "the indisputable bedrock of the quarrel between London and Brussels".
And this is Anderson's "bedrock":
The European Union, as it has come to take shape, speaks continuously of democracy and the rule of law, even as it negates them. No ill intention need be ascribed to it. What it has become is inscribed in the minds of those who took possession of the project: a unification of the Continent from above, by stealth where possible, by diktat where necessary... Of the 27 countries currently comprising the Union, none has a continuous parliamentary history comparable to the record in England.
The fundamental Eurofudge
Anderson has a low opinion of the "fundamentally oligarchic" European ruling caste: "its top ranks have long been corrupted by immunity in their occupance of power". He cites a series of allegations and convictions: of malversation of public funds, sexual assault, embezzlement, plagiarism, involvement in tax avoidance, concealment of payments, receipt of suspect donations and unwise intimacy with major fraudsters. These "tawdry episodes" should not be "generalised to the whole European political class"; yet "where Europe is concerned, there is rarely a contradiction between self-interest and genuine idealism".
The union's underlying premise "is the passivity of the population below the political class and its adherents". Moreover, "the centrist bloc of opinion encompassing moderate conservative, temperate liberals, pragmatic social democrats and self-satisfied Greens... is much larger than its opponents on right or left, and remains overwhelmingly dominant in the Union".
External events and forces have frequently shaped the centralising impetus of the EU. The pandemic is no different. Now the 'Next Generation EU' package of €750bn "has been hailed as a breakthrough by [Dutch writer Luuk] van Middelaar", who observes that Merkel has broken "the last two taboos of German monetary thinking: collective debt and outright grants; for just this once; but in Paris and Berlin they know that whoever crosses this bridge once can do it more often: the precedent is set".
How what Anderson calls this "powerful forward motion" will develop is not certain. A federalist superstate seems unlikely, and some kind of federal pan-European political union combined with common economic and security policies for a like-minded inner group seems even more remote. The federalist goal has "never been achieved; but nor... has the incremental progress towards that end ever been stopped or reversed – is it credible that it has now reached its limit?
"Or is the current formulation of the EU – dilute sovereignty without meaningful democracy, compulsory unanimity without participant equality, cult of free markets without care of free trade – likely all the same to last indefinitely?"
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Background. Adolescence is a critical period of growth and different variables can effect on this process in this age period. The relationship between obesity in adolescence and some metabolic disorders in the future has been reported by many studies. This study was carried out to determine the pattern of fat distribution among high school adolescents in Ilam city in 2013. Method. In this cross-sectional study, 583 high school students were selected with a dedicated multi-stage stratified random sampling method. Weight, height, waist and hip circumferences were measured and BMI and WHR were calculated. Results: The prevalence of being overweight, obesity and abdominal obesity were 21.8 %, 0.7 %, and 39.8% respectively. Age of students showed a significant positive and negative correlation with BMI and WHR (P<0.001). Conclusion: Results of this study showed that adolescents are at increased risk for overweight and obesity. Therefore monitoring the health and nutrition, nutrition education, improve knowledge and sporting for this age group may help to improve health, nutrition and the prevention of many chronic diseases in adulthood.


We write in response to the petition of Mr. Chipman L. Flowers, Jr. and The Archives of the Honorable Chip Flowers, Jr. (collectively "Mr. Flowers"), dated August 4, 2015 ("Petition"). In the Petition, Mr. Flowers argues that the Office of the State Treasurer ("OST") committed multiple violations of the Delaware Freedom of Information Act, 29 Del. C. §§ 10001-10007 ("FOIA") in connection with its handling of Mr. Flowers' requests for emails sent from or received at his state email address during his tenure as State Treasurer.
In this determination, we conclude that OST did commit one such violation based on its misunderstanding of the term "legal review" as used in the statute. We prescribe remediation for the violation.
Mr. Flowers served as the State Treasurer for the State of Delaware from 2011 to 2015. During that time, Mr. Flowers used a State email address. In 2015, Mr. Flowers asked OST to review every email Mr. Flowers sent from or received in his State email account during his four-year term of service and to provide to him a copy of every email, or portion thereof, that is not protected by a statutory exemption under FOIA or other Delaware or federal law. After de-duplication, the total number of emails in this set appears to exceed 19,000.
On January 26, 2015, the Delaware Division of Technology and Information ("DTI") sent OST's FOIA Coordinator an estimate regarding Mr. Flowers' January 6 request. Specifically, DTI estimated a cost of $100 to extract the potentially responsive records, load them to a CD, and deliver the CD to OST. DTI noted that OST would be responsible for any redactions. That same day, OST's FOIA Coordinator forwarded the email to Mr. Flowers and noted that the check should be sent to DTI.  Moments later, Mr. Flowers indicated that he would send the check.
On February 3, 2015, OST's FOIA Coordinator responded that OST was in receipt of, but had not yet reviewed, approximately 24,000 potentially responsive emails from DTI. OST's FOIA Coordinator stated that "[g]iven this volume, it will take a significant amount of time to review each of the[ ] emails initially and determine which e-mails or parts of e-mails falls within the exemptions under FOIA that warrant exclusion or redaction." OST's FOIA Coordinator did not provide an exact estimate, but, as requested, he informed Mr. Flowers that the cost would exceed $500.00. The FOIA Coordinator asked Mr. Flowers whether he wished to narrow his request to a more specific set of e-mails in order to reduce costs and review time.
I have to review them as well—which is where the lion's share of the charge would come from. DTI retrieved all e-mails sent to or by Chip.Flowers@delaware.gov. There are duplicate e-mails in the 24,000 but I still have to go through each one because sometimes a reply to the original email will be shown under the same subject line. These e-mails were provided in the form of attachments. Just opening the e-mails would take a considerable amount of time (estimate 5-6 seconds just to get the attachment open multiplied by 24,000). We are willing to comply with the request but the cost will go well beyond the $500 mark simply due to the sheer volume of the original request. We are happy to discuss this with you over the phone.
OST's response copied Delaware State Treasurer Ken Simpler.
Mr. Flowers' reply indicated a willingness to discuss narrowing his request. He stated: "Good deal. It's probably fine on my end. We can discuss to try to narrow it down. I should have time to call you in the am. Does the morning work for both of you?" Moments later, Treasurer Simpler replied, requesting that Mr. Flowers talk to Mr. Masood to see if they could narrow the scope. He added: "I just wanted you to know that we are trying to be responsive." On February 4, 2015, the date of the scheduled telephone call, Mr. Flowers informed OST that he had decided not to modify his request at that time.
Instead, on February 5, 2015, Mr. Flowers submitted a second FOIA request to OST, seeking a much broader scope of records (the "February 5 Request"). Specifically, he sought "[c]opies of all electronic mails sent to and from State Treasurer Chip Flowers from January 2011 – January 10, 2014 (including, [sic] electronic emails put on 'litigation hold' from the Delaware Department of Justice beginning in 2013)." Although he had been informed two days earlier that his smaller request would likely cost more than $500.00 to fulfill, Mr. Flowers again requested that he be contacted if the cost would be greater than $500.00.
On February 18, 2015, a DTI representative sent OST an estimate regarding Mr. Flowers' February 5 Request. DTI again estimated a cost of $100 to extract the potentially responsive records, load them to a CD, and deliver the CD to OST. The correspondence noted that DTI generally retains a user's email for only 12 months, but that more of Mr. Flowers' emails may be available because of a November 2012 litigation hold. That same day, OST's FOIA Coordinator forwarded the estimate to Mr. Flowers and noted that the $100 would be in addition to the $100 charge for the January 6 request. Mr. Flowers copied his Director of Finance and Operations on his response and instructed her to send the $100 check to DTI.
According to the Delaware Department of Technology and Information (DTI), there are 23,554 e-mails. At an estimated 2 minutes expended per e-mail for time spent reading, printing and redacting, it would take an estimated 785.13 hours of administrative staff time to complete this request. At a rate of $13.42 per hour, which is the current hourly pay of the lowest-paid employee capable of performing this service, the cost for administrative fees is $10,536.44. Using an estimate of 2 pages per e-mail, photocopying would cost $4,708.80 to copy 47,108 pages. The combined cost is $15,245.24, exclusive of any fees owed to DTI.
On February 26, 2015 Mr. Flowers expressed his concerns about OST's fee estimate in an email to OST's FOIA Coordinator. Mr. Flowers challenged the idea that anyone would be required to look at all of the emails he requested. He identified several categories of emails that, in his view, should not be reviewed at all or should not be part of the fee estimate. For example, Mr. Flowers argued that any email sent to him by a third party could not be protected by the attorney-client privilege and, therefore, need not be reviewed by anyone before delivery to Mr. Flowers. Likewise, Mr. Flowers stated that any communications that might be protected by the attorney-client privilege would have to be reviewed by OST's counsel, and OST could not charge fees for this "legal review." Finally, Mr. Flowers contended that any emails that had been released by OST in response to any earlier FOIA request or had otherwise been disclosed publicly would not require any review before providing the same emails to Mr. Flowers.
OST's counsel also informed Mr. Flowers that OST had requested, but had not yet received, the emails responsive to the February 5 Request. OST's counsel stated that she anticipated that OST would offer the same review alternative with respect to those emails. She also confirmed that if OST's alternative review proposal was not acceptable to Mr. Flowers, the February 18 cost estimate continued to remain an option.
To accomplish a narrowed search, it would be necessary for you to first determine the scope of the search and those terms that are to be included and excluded. Because this would entail a search with special scripts written by DTI, which is more time intensive for DTI and costlier, DTI cannot provide an estimate for the costs associated with a narrowed/special script search until you provide this additional information. Therefore, please advise of the scope and terms of your narrowed search. Once the OST receives a sufficient response from you regarding a narrowed search, the OST will promptly submit a request to DTI for this final search. . . .
All electronic mail correspondence to, from and cc'ing State Treasurer Chip Flowers from any non-Delaware government source (including communications from the White House and other federal and non-Delaware agencies), excluding emails to, from or cc'ing (i) any state employee (designated by the extension – state.de.us in "To"; "CC" or "BCC" field) other [sic] Ms. Kelly Callahan or (ii) Clark Collins, Esq. (morrisjames.com). The information relating to Clark Collins will be discussed at a later date in the broader context of privilege.
We are willing to narrow our request for electronic mail communications involving state officials to exclude (i) any communications either to, from or cc'ing any staff personnel of the Board of Pardons (from our knowledge, this would involve only two individuals, Judy and Diane from the Board of Pardons – not the Board members), (ii) communications either to, from or cc'ing any member of the General Assembly that served at the time of State Treasurer's term in office, (iii) communications either to, from or cc'ing any staff personnel from the Delaware Farmland Preservation Board (not the Board members) and (iii) communications either to, from or cc'ing Amy Bonner or Kevin (AG). My apologies as I do not recall Kevin's last name.
All electronic mail correspondence to, from and cc'ing State Treasurer Chip Flowers provided under any FOIA issued during his term in office (this would include information relating to former Deputy State Treasurer Erika Benner and other information provided to individuals set forth in the Treasury's FOIA log).
All electronic mail correspondence to, from and cc'ing State Treasurer Chip Flowers from any cabinet secretary or statewide elected official that did not copy a member of the Office of the Attorney General (the applicable members of the Attorney General should be easily obtained – Annmarie Johnson, Frank Broujos, Laura Gerard, Elio Battista, Ed Black, Aaron Goldstein, Attorney General Beau Biden, Kathy Jennings, Tim Maloney and those individuals in the office that were "investigating" or "assigned" to the Treasury – call it a hunch, but we feel very confident that your office could provide a complete list of names to DTI for this search, including members of the AG's Special Investigative Unit assigned to the Treasury).
Once we hear from you, OST will communicate your newly provided search terms . . . to DTI. However, it is not at all clear to us that those search terms will address, with certainty, the exclusion of confidential non-public records (i.e. emails) to which you are not entitled, thereby reducing the number of responsive emails for review prior to providing you access.
OST otherwise repeated several of the positions it had taken in its March 17, 2015 correspondence and offered to provide to Mr. Flowers the non-confidential, non-privileged emails between Mr. Flowers and Deputy Treasurer Erika Benner that OST had previously provided to the News Journal.
Mr. Flowers responded promptly to OST's counsel and asked her to speak directly with Mr. Flowers' FOIA Counsel. He stated that, from his perspective, the FOIA requests were clear. He asked OST to produce the documents or to explain in writing any objections to his four searches so that he could pursue an appeal. Finally, Mr. Flowers indicated that the question of who within the Attorney General's Office was assigned to the Treasury was a question for OST's counsel.
The next day, however, April 14, 2015, Mr. Flowers sent an email to OST's counsel to identify email search software that he believed would assist DTI with the searches and avoid what he deemed a "grossly unreasonable" search fee of $100 or $200 per additional search. Mr. Flowers explained that "his technology company" told him that technology was available to assist with the project. Mr. Flowers provided OST with a link to the software and stated that he was willing to pay the $200 cost for the software.
It is OST's position that regardless of the search terms utilized, confidential emails may have been pulled and burned to the CD. Therefore, without OST (and/or its counsel) reviewing each of the 22,107 emails, OST believes the access [offered by OST's counsel on February 27] constitutes "reasonable access" required by FOIA (by providing immediate access and avoiding significant additional cost to Mr. Flowers for OST's review of the emails) and fulfills this request. . . .
OST's counsel took a similar tack with Mr. Flowers' February 5 request, stating: "[N]o set of search terms (whatever they are) will exclude all potentially confidential emails – emails that cannot be turned over to anyone without OST's initial review and redaction (if necessary)." OST's counsel offered to make the emails available under the same conditions as the emails responsive to Mr. Flowers' January 6 request. OST's legal counsel stated that, "[o]ther than reviewing and providing (redacted if necessary) copies of the emails Mr. Flowers selects during his on-site review," OST would consider the requests closed.
The record does not reveal whether the parties had communications between May 9 and May 28, 2015. On May 28, 2015, Mr. Flowers sent an email to Treasurer Simpler and OST's FOIA Coordinator, asking OST to provide him with a detailed plan for delivering all statutorily required documents "within five (5) business days or legal action w[ould] be forthcoming." He added that he was willing to offer OST a document delivery schedule for the release of all relevant documents over a period of six months. Again, Mr. Flowers did not suggest any change in his position on OST's fee estimate.
Mr. Flowers' counsel replied promptly that "Mr. Flowers' legal team [wa]s conferring on an appropriate response" to OST's June 9 email and stated that "such response w[ould] be forthcoming shortly." The record does not reveal whether the parties had communications between June 10 and July 29, 2015.
On July 29, 2015, a new attorney representing Mr. Flowers ("Petition Counsel") sent a letter to OST's counsel: "seeking clarification of OST's position," "to request an itemized written cost estimate of any fees expected to be incurred," and "to propose a reasonable path forward toward amicably resolving this matter." The July 29 letter set forth Mr. Flowers' legal position and stated that if OST declined to engage in the proposed resolution, Mr. Flowers would appeal the matter to the Attorney General's Office and/or the Delaware Superior Court.
On August 3, 2015, the parties conducted a teleconference. The record does not summarize the discussion, but Mr. Flowers' Petition suggests that some of the parties' issues may have been mooted or clarified. Likewise, OST described the teleconference as "productive (and extensive)." Nevertheless, Petition Counsel informed OST during the call that Mr. Flowers would be filing a petition with the Attorney General's Office the next day to "preserve" an appeal. Mr. Flowers filed his Petition the next day.
OST responded to the Petition on August 17, 2015 (the "Response"). On August 24, 2015, we asked OST to submit additional argument, which it did on September 11, 2015 (the "Supplemental Response").
Finally, Mr. Flowers wrote to this Office on August 27, 2015, to clarify the nature of his request. Mr. Flowers stated clearly that he does not want "a selected subset of the non-exempt documents." Rather, Mr. Flowers argued that every email in OST's possession is "necessarily and admittedly responsive" and that the only determination to be made is whether "any are exempt from public disclosure." Stated another way, Mr. Flowers wants to have at the end of the process a collection of emails that OST and its counsel have determined are available for public display.
Mr. Flowers asked this Office to "investigate OST's Response for violations of FOIA." We did not do so, as that is not our statutory mandate.
Mr. Flowers also argued that OST violated FOIA by: (1) including in its cost estimate fees for OST's "legal review" of emails and for printing emails (the latter because Mr. Flowers specifically requested an electronic copy); (2) including photocopying fees in its cost estimate; (3) failing to provide any cost estimate in connection with Mr. Flowers' February 5 Request; (4) "demanding" that Mr. Flowers perform an initial review of the emails to determine the applicability of FOIA exemptions; (5) circumscribing Mr. Flowers' access to the requested emails based upon an erroneous belief that he "already possesses" copies of some of the emails; and (6) engaging in "obstinate tactics." Mr. Flowers requests an award of attorneys' fees and costs.
Although Mr. Flowers argued several times to OST that he was entitled to receive certain categories of emails without any prior review by OST or its counsel, Mr. Flowers did not challenge the fee estimate on this basis in his Petition to this Office.
In its Response, OST argues that this Office may resolve a "threshold" argument and avoid consideration of Mr. Flowers' individual arguments. OST contends that the invitation to allow Mr. Flowers to inspect and cull the emails before OST undertakes any review constitutes "reasonable access" under FOIA and satisfies OST's statutory obligations in itself. OST also notes that this offer was presented only after Mr. Flowers disputed OST's fee estimate and refused any further negotiation of search terms. Finally, OST contests each of Mr. Flowers' arguments. We address both parties' arguments in greater detail below.
It is vital in a democratic society that public business be performed in an open and public manner so that our citizens shall have the opportunity to observe the performance of public officials and to monitor the decisions that are made by such officials in formulating and executing public policy; and further, it is vital that citizens have easy access to public records in order that the society remain free and democratic. Toward these ends, and to further the accountability of government to the citizens of this State, [Title 29, Delaware Code, Chapter 100] is adopted, and shall be construed.
Prior to disclosure, records may be reviewed by the public body to ensure that those records or portions of records deemed nonpublic may be removed pursuant to § 10002 of this title or any other applicable provision of law.
Administrative fees shall be levied for requests requiring more than 1 hour of staff time to process. Charges for administrative fees may include staff time associated with processing FOIA requests, including, without limitation: identifying records; monitoring file reviews; and generating computer records (electronic or print-outs). Administrative fees shall not include any cost associated with the public body's legal review of whether any portion of the requested records is exempt from FOIA. The public body shall make every effort to ensure that administrative fees are minimized, and may only assess such charges as shall be reasonabl[y] required to process FOIA requests. In connection therewith, the public body shall minimize the use of non-administrative personnel in processing FOIA requests, to the extent possible.
Prior to fulfilling any request that would require a requesting party to incur administrative fees, the public body shall provide an itemized written cost estimate of such fees to the requesting party, listing all charges expected to be incurred in retrieving such records. Upon receipt of the estimate, the requesting party may decide whether to proceed with, cancel, or modify the request.
Delaware's FOIA provides that, "[p]rior to fulfilling any request that would require a requesting party to incur administrative fees, the public body shall provide an itemized written cost estimate of such fees to the requesting party, listing all charges expected to be incurred in retrieving such records." This allows the requesting party to "decide whether to proceed with, cancel, or modify the request" before incurring any fees.
Mr. Flowers alleges that OST violated FOIA by offering an inflated estimate of administrative fees to be incurred in connection with his first request. Specifically, he alleges that the estimate includes time for OST's "legal review" of the records, which is prohibited under the statute, and a fee for printing that is improper because Mr. Flowers requested an electronic copy of the records. Mr. Flowers also contends that OST inflated its estimate by including printing fees. Mr. Flowers argues that the foregoing charges violate FOIA's requirements that public bodies ensure that administrative fees are minimized and assess only those charges reasonably required.
As set forth more fully below, we agree with Mr. Flowers that OST's fee estimate included time required for legal review, for which Mr. Flowers may not be charged. We cannot conclude, however, that including printing fees in the estimate was a violation of FOIA.
. . . Charges for administrative fees may include staff time associated with processing FOIA requests, including, without limitation: identifying records; monitoring file reviews; and generating computer records (electronic or print-outs). Administrative fees shall not include any cost associated with the public body's legal review of whether any portion of the requested records is exempt from FOIA . . . .
This provision first enumerates specific tasks, administrative in nature, for which administrative fees may be charged. In contrast, the next sentence identifies the "legal review of whether any portion of the requested records is exempt from FOIA" as a task for which administrative fees may not be charged.
Based upon the foregoing, we conclude that OST violated FOIA to the extent that OST's fee estimate anticipated time spent for OST's FOIA Coordinator to, in OST's words, "determine which e-mails or parts of e-mails falls within the exemptions under FOIA that warrant exclusion or redaction," or, in OST's counsel's words, "review (for FOIA exemptions other than attorney-client privilege)." We believe that the appropriate remediation is for OST to provide Mr. Flowers with a revised itemized written estimate in accordance with the guidance provided in this determination. The fee estimate may include fees associated with OST's FOIA Coordinator's time spent performing administrative tasks such as removing or redacting records in accordance with a set of instructions provided by counsel, but it should not include any fees associated with any review for a determination of whether FOIA exemptions apply.
Given that there is now a single, de-duplicated data set for both of Mr. Flowers' requests, we determine that OST should prepare the estimate (and conduct the review) using this set. Although Mr. Flowers actually submitted two requests, the record suggests that there is considerable overlap in the data sets. Reviewing the two sets separately would result in unnecessary and unfair charges to Mr. Flowers, and would not satisfy the statute's direction to minimize administrative fees.
This Office has previously stated that "a public body cannot respond to a request for information in electronic form by supplying paper records that contain the same information." In that matter, it appears that the requesting party asked for records contained in an electronic database and the public body provided the records in hard copy instead. The public body argued that it was only required by law to maintain hard copies, and it therefore was only required to provide the documents in hard copy. That is not what OST proposes to do here. OST argues that it must print emails in order to review and redact them. OST then intends to provide the records to Mr. Flowers in electronic form.
We do not read FOIA to impose a blanket ban on printing (or photocopying) fees – or on fees for the administrative time it takes to print or make photocopies of emails – every time a requesting party asks for an electronic copy of records. The determination is fact-specific. For example, not every public body will have document review software that permits online review and redaction of electronic records. If a public body does have such software, then we would agree that it could not refuse to use that software in order to charge fees or to increase the amount of time required to process a FOIA request. If, however, a public body must conduct a review and redact documents without such software, then we believe it will have no choice but to print the documents, redact them by hand, and then photocopy or scan the documents before they may be delivered to the requesting party. Importantly, we do not read FOIA to require a public body to purchase technology in order to respond to a request for records.
Under the circumstances, we cannot conclude that OST committed a violation of FOIA by including printing charges in its estimate. OST has specifically represented that it would continue to evaluate options for conducting electronic review, but that it currently does not have the ability to redact emails in their electronic form and must instead print the emails and make necessary redactions on paper. Should OST uncover an ability to conduct electronic review and redaction for some or all records, the revised estimate may exclude such fees, but we find that OST made a good faith effort in the challenged estimate.
Mr. Flowers also alleges that OST violated FOIA by including an estimate of photocopying fees because Mr. Flowers has requested an electronic copy of the emails. For the reasons set forth above, we cannot conclude that OST's inclusion of photocopying fees in its estimate amounted to a violation of FOIA. OST has indicated an intention to conduct its review according to a standard procedure and to provide the documents in electronic form. We accept this representation. Finally, we note that records redacted by hand commonly require photocopying. Thus, on this record, we cannot say that including photocopy charges in the estimate was unreasonable or that doing so constituted a violation of FOIA. Of course, the matter can be assessed again after the review is completed, and it will be much easier to determine whether any photocopy charges were necessary or reasonable.
Mr. Flowers next argues that OST violated FOIA by failing to prepare an estimate of charges in connection with his second request, which was submitted on February 5, 2015. We disagree.
As an initial matter, we note that FOIA does not specify that the written cost estimate be provided at any particular time, but requires that an estimate be provided "[p]rior to fulfilling any request that would require a requesting party to incur administrative fees." The purpose, we believe, is to prevent a public body from incurring charges that may be imposed upon a requesting party without notice and an opportunity to avoid or minimize the charges. The record reveals that OST was not taking any action unapproved by Mr. Flowers in connection with the second request.
In addition, the record reveals that the parties were negotiating and attempting to reduce the overall potential cost to Mr. Flowers until the date he filed the Petition. On February 27, 2015, OST proposed to allow Mr. Flowers to review documents responsive to Mr. Flowers' January 6 Request in person. In the same correspondence, OST's counsel noted that OST had requested, but had not yet received, the emails responsive to Mr. Flowers' February 5 Request. Under the circumstances, no estimate would be required, or possible, until Mr. Flowers rejected OST's proposal (or agreed and conducted an initial review) and OST knew the number of emails that would be returned pursuant to Mr. Flowers' February 5 Request.
We believe that the parties reached an impasse regarding OST's proposal to have Mr. Flowers conduct an initial review of the documents responsive to his January 6 Request as early as May 9, 2015. Perhaps OST could have inferred at that time that Mr. Flowers was anticipatorily rejecting the proposal as to the February 5 Request. But OST was not aware of the number of emails that DTI would return in connection with the February 5 Request until June 9, 2015. Thus, we believe that June 9 was the absolute earliest date upon which OST might have delivered an estimate.
We find that the failure to provide an estimate on that date or between June 10 and the date of the Petition (August 4, 2015) does not constitute a violation of FOIA under the circumstances. The record suggests that OST, having provided Mr. Flowers with new information on June 9, was waiting to see how Mr. Flowers would respond. When he did respond, through new counsel, Mr. Flowers requested another discussion, set forth the conditions upon which he would move forward, and requested the fee estimate he seeks. Five days later, the parties conducted the requested discussion, and the following day, Mr. Flowers filed his Petition. On this record, we find no violation of FOIA for having failed to prepare a fee estimate for the February 5 Request.
For the reasons set forth earlier, we do not believe that OST may fairly review two separate data sets with a significant number of duplicates. Thus, two separate estimates would provide no useful information to Mr. Flowers. The revised estimate that we call for in remediation of OST's FOIA violation should relate to the de-duplicated data set.
Mr. Flowers contends that OST has improperly demanded that he perform an initial review of the records "and remove what [Mr. Flowers] alone believed to be non-public documents . . ." This is not supported by the record. As OST correctly notes: "OST has never demanded, or even suggested in any context, that Mr. Flowers perform an initial review of the requested emails for exemptions under FOIA." Rather, OST's counsel offered to allow Mr. Flowers to review all potentially-responsive documents and to identify a subset of emails that he wished to obtain. OST would then review that smaller set of emails for FOIA exemptions.
We therefore determine that OST did not violate FOIA on this basis as alleged in the Petition.
Mr. Flowers alleges that OST violated FOIA by "reject[ing]" or "circumscrib[ing]" access to the requested records on the basis that Mr. Flowers already obtained a complete set of his un-redacted email correspondence when he left office.  Mr. Flowers argues that he does not have copies of the emails and that, even if he did, it would not matter because what he wants are "documents that are available for public disclosure, which is different…." Stated another way, even if Mr. Flowers has copies of his emails, he cannot mitigate the risks of displaying the emails in his public archive unless, as he has done here, he receives the records through the FOIA process and requires the State to review them.
Mr. Flowers' specific allegation is that OST has taken two different approaches to the manner in which it will review emails, based upon whether it believes that Mr. Flowers has the emails in his possession or not. The difference in the approach, it appears, is whether OST will take the "ordinary" approach of reviewing the emails and providing only what is appropriate or will ask Mr. Flowers to take the "alternative" approach of reviewing emails first to see whether any might be unnecessary to his archive project.
In our view, OST has neither "rejected" nor "circumscribed" Mr. Flowers' access to records by making the distinction it has made and has committed no FOIA violation. The "alternative" approach made its appearance in this case long before OST made any mention of its belief that Mr. Flowers possesses copies of the emails he seeks. As we have stated, the reason for the offer was to attempt to diminish the number of emails that OST and its counsel would have to examine and prepare for production, thereby potentially diminishing the costs to Mr. Flowers. The pool of emails that OST later proposed to review in the "ordinary" way concerns a period of three weeks and, we presume, will be much smaller in size. Thus, based on this record, it appears that OST took this position to be helpful and because doing so would not likely create a significant charge for Mr. Flowers.
We therefore find that OST did not violate FOIA on this basis as alleged in the Petition.
Mr. Flowers contends that OST violated FOIA by "[t]hreatening to impose substantial costs for review while at the same time ambiguously stating that no costs for 'legal review' would apply." In addition, Mr. Flowers argues that OST's FOIA coordinator has "utterly failed" to meet his statutory obligation to foster cooperation between the agency and Mr. Flowers and that he "rebuffed every attempt at cooperation by the Requestors and every proposed path forward to lessen OST's burden." We do not read the record as Mr. Flowers does.
We have determined that OST's cost estimate violated FOIA to the extent that it included time to be spent on "legal review." We believe OST had too narrow a view of the meaning of "legal review" (as, we believe, did Mr. Flowers). However, we note that OST's fee estimate predated this Office's determination in Del. Op. Att'y Gen. 15-IB03, and we see nothing in the record that amounts to a threat, explicit or veiled, by any state employee to impose inappropriate charges upon Mr. Flowers in order to discourage Mr. Flowers from pursuing his Requests under FOIA.
Neither have we found evidence in the record demonstrating that OST's FOIA Coordinator failed to meet his statutory obligation to foster cooperation between the agency and Mr. Flowers, or "rebuffed every attempt at cooperation" made by Mr. Flowers. As stated above, Delaware's FOIA requires that a public body's FOIA Coordinator "serve as the point of contact for FOIA requests and coordinate the public body's response thereto." In addition, the FOIA Coordinator must "work to foster cooperation between the public body and the requesting party," and "make every reasonable effort to assist the requesting party in identifying the records being sought, and to assist the public body in locating and providing the requested records." Contrary to Mr. Flowers' assertions, the record demonstrates that the FOIA Coordinator made good faith attempts to fulfill his duties as he understood them.
Based upon the foregoing, we have determined that OST violated FOIA to the extent that the fee estimate for Mr. Flowers' January 6 Request included charges for "legal review." As to all other matters raised, we determine that OST did not violate FOIA.
As remediation, we ask OST to provide Mr. Flowers with a revised written estimate following the guidance provided in this determination. As set forth above, the fee estimate shall exclude any fees for OST's legal review. The fee estimate may include fees associated with OST's FOIA Coordinator's time spent performing administrative tasks such as removing or redacting records in accordance with a set of instructions provided by counsel, but it should not include any fees associated with any review for the purpose of determining whether FOIA exemptions apply.
Because there is a de-duplicated and substantially reduced data set sufficient to satisfy both of Mr. Flowers' requests, we ask OST to prepare the revised estimate and conduct its review using this set of approximately 19,000 emails.
This letter is directed solely to the parties identified herein. It is based on the facts relevant to this matter and, as such, should not be cited as binding precedent by future parties.
Either party may appeal adverse determinations to the Superior Court within 60 days of the date of this letter.
 Letter from P.C. Collins, Jr. to D. Gibbs dated August 27, 2015 ("[T]he Requestors seek each and every record responsive to the Requests that is not exempt from public disclosure.").
 Response at 10, 13 n. 61; Ex. 30 at 1-2 (Email from F. Broujos to K. Council dated June 9, 2015 (4:28 PM)).
 Mr. Flowers alleges that "[t]he Archives was established to archive Mr. Flowers' significant achievements and contributions during his term as State Treasurer" (Petition at ¶ 7), that "[d]ocuments, writings, photographs, correspondence, recordings and materials from his historic campaign and term as State Treasurer would be made available via the Archives' website on an ongoing basis through the Flowers Papers Project" (Petition at ¶ 8), and that "[i]n connection with these discussions and in furtherance of the work of the Flowers Papers Project, the Requestors sent Flowers FOIA #1 To OST's FOIA coordinator, Omar Masood, in early January 2015" (Petition at ¶ 10). Cf. Petition at ¶ 9 ("Around the same time, Mr. Flowers was also engaged in discussions with institutions to arrange for the donating of his correspondence compiled during his term of office for educational and historic research. These discussions are currently ongoing with at least one highly distinguished educational institution and one government agency."); Letter from P.C. Collins, Jr. to D. Gibbs dated August 27, 2015 ("[Requestors'] objective is to compile a comprehensive collection of Mr. Flowers' correspondence to be donated for archival or research purposes.").
 The Petition included 32 exhibits, which consist largely of email chains. We assume the use of chains was intended to reduce the total number of exhibits submitted, but the effect is to make it difficult for a reader to discern which communications we cite. Accordingly, for ease of reference, all citations to Mr. Flowers' exhibits include parenthetical cross-references to the specific communication cited herein. Additionally, while a particular communication may appear in multiple exhibits, we have cited to the first exhibit in which the communication appears.
 Ex. 26 at 2 (Email from C. Flowers to O. Masood dated January 6, 2015 (10:36 AM)).
 Ex. 33 at 1 (Email from O. Masood to C. Flowers dated January 6, 2015 (10:54 AM)).
 Ex. 34 at 3 (Email from Elayne Starkey to O. Masood and A. Richardson dated January 26, 2015 (10:02 AM)).
 Id. at 3 (Email from O. Masood to C. Flowers dated January 26, 2015 (3:11 PM)).
 Id. at 2 (Email from C. Flowers to O. Masood dated January 26, 2015 (3:19 PM)).
 Ex. 1 at 3 (Email from O. Masood to C. Flowers dated February 3, 2015 (1:05 PM)).
 Id. (Email from C. Flowers to O. Masood dated February 3, 2015 (1:20 PM)).
 Id. (Email from O. Masood to C. Flowers dated February 3, 2015 (3:13 PM)).
 Id. at 2 (Email from C. Flowers to O. Masood dated February 3, 2015 (3:18 PM)).
 Ex. 2 at 1 (Email from K. Simpler to C. Flowers and O. Masood dated February 3, 2015 (3:36 PM)).
 Ex. 3 (Email from O. Masood to C. Flowers dated February 18, 2015 (1:24 PM)). We note that this correspondence does not indicate whether Mr. Flowers communicated his decision before, during, or after the telephone call scheduled for February 4, 2015.
 Ex. 26 at 3 (Email from C. Flowers to O. Masood dated February 5, 2015 (11:58 AM)).
 Ex. 4 at 2 (Email from S. Alexander to A. Richardson dated February 18, 2015 (8:47 AM)).
 Id. (Email from O. Masood to C. Flowers dated February 18, 2015 (1:25 PM)).
 Id. at 1 (Email from C. Flowers to O. Masood dated February 18, 2015 (1:37 PM)). On February 20, 2015, Mr. Flowers' Director of Finance and Operations responded that "[t]he payment of $200 was mailed this week." Id.
 Ex. 3 (Email from O. Masood to C. Flowers dated February 18, 2015 (1:24 PM)).
 Ex. 5 at 4-5 (Email from C. Flowers to O. Masood dated February 26, 2015 (12:00 PM)).
 Id. at 5 ("We will resist any Treasury effort to claim that all emails and documents received and sent by me need to be reviewed as the definition of the statute limits what could be deemed protected and technology exists to limit the search to those applicable documents."). We note that the subject line of the email states "Email Resent without Typos." In the email, Mr. Flowers stated that a prior email had been sent from his wireless device and that the corrected text had been noted. Based upon the context, we assume that the bolded and underlined words in this email are intended to emphasize those corrections.
 Id. (". . . As you may know, many of the documents sent and received by me were from third parties and would not be subject to privilege or protection by definition and would not need to be reviewed.").
 Id. ("Further, any emails and documents relating to legal privilege (where a AG office member was copied) would need to be reviewed by the Attorney General's office for such determination as to whether the privilege was mine (which means the email and attached document could be disclosed) or the privilege belonged to the state and no charge would be attributed to me for such review as there is no charge for legal review by the Attorney General's Office.").
 Id. ("Finally, many emails and documents have already been reviewed due to prior FOIA requests or were already disclosed publicly and therefore no additional review is required and such emails and documents should be disclosed immediately."). We read Mr. Flowers' argument to be that emails released to other parties in response to earlier FOIA requests necessarily constitute "public records" and may not be withheld from a subsequent requesting party. OST did not address this argument, and we express no opinion here.
 It is perhaps needless to say that OST's counsel is entitled to conduct its own legal analysis.
 Ex. 5 at 3-4 (Email from L. Gerard to C. Flowers dated February 27, 2015 (2:31 PM)).
 Id. at 2 (Email from C. Flowers to L. Gerard dated February 27, 2015 (2:47 PM)).
 Id. To repeat, Mr. Flowers' concept of "narrowing" was that certain categories of emails would be provided without any review by OST or its counsel.
 Id. at 1 (Email from C. Flowers to L. Gerard dated March 16, 2015 (3:26 PM)).
 Ex. 6 at 1-2 (Email from L. Gerard to C. Flowers dated March 17, 2015 (4:31 PM)).
 Id. at 1. Here it appears that OST's counsel used the concept of a "narrowed search" in the manner that most people would, but not in the manner that Mr. Flowers used the term.
 See Ex. 12 at 3-8.
 Id. at 1 (Email from C. Flowers to F. Broujos and K. Council dated April 6, 2015 (12:36 PM)).
 Ex. 11 at 1 (Email from C. Flowers to F. Broujos and K. Council dated April 6, 2015 (12:29 PM)).
 Id. The second search request did expressly narrow the request for "electronic mail communications involving state officials" by excluding four categories of communications.
 Ex. 13 at 1 (Email from L. Gerard to C. Flowers and K. Council dated April 13, 2016 (4:00 PM)).
 Id. Counsel stated that "no non-public records will be released – – to anyone – – by OST" including "requested emails that are exempt under FOIA due to confidential content." Id. Additionally, "[a]ll other public records . . . that may be subject to attorney-client privilege (existing between [Mr. Flowers] as Treasurer and [his] counsel) w[ould] be made available to [Mr. Flowers] (and only [Mr. Flowers]) for review only . . . at a mutually convenient time." Id. Counsel stated that OST would thereafter review any records requested by Mr. Flowers as a result of his review. Id.
 Id. The parties eventually reached agreement on this point, and OST sent the records to Mr. Flowers' FOIA Counsel. See Ex. 22 (Email from O. Masood to K. Council dated April 28, 2015 (3:16 PM)). Mr. Flowers was copied on the correspondence.
 Ex. 14 at 1 (Email from C. Flowers to L. Gerard and K. Council dated April 13, 2015 (4:31 PM)).
 See id. ("We encourage you to review each paragraph provided to start the process or submit us a letter setting forth the reasons why such information can't be provided, so we can file an appeal and keep the process moving via the Court.").
 Ex. 15 at 1 (Email from C. Flowers to L. Gerard and K. Council dated April 14, 2015 (11:39 AM)).
 Id.; Ex. 16 at 1 (Email from C. Flowers to L. Gerard and K. Council dated April 14, 2015 (11:44 AM)).
 See Ex. 23 (Email from F. Broujos to K. Council dated April 28, 2015 (5:06 PM)); Ex. 25 (Email from K. Council to F. Broujos and L. Gerard dated April 30, 2015 (11:54 AM)).
 Ex. 25 (Email from K. Council to F. Broujos and L. Gerard dated April 30, 2015 (11:54 AM)).
 Ex. 26 at 1 (Email from F. Broujos to K. Council dated May 8, 2015 (5:01 PM)).
 Id. at 3 (emphasis in original). We read the foregoing sentence as an offer: OST or its counsel would review all emails (as in the ordinary course of processing FOIA requests) or Mr. Flowers could review the emails first and identify a potentially smaller set of records for OST or its counsel to review.
 See Ex. 28 at 3 (Email from C. Flowers to K. Council dated May 9, 2015 (9:01 AM)). We note that OST's counsel was copied on this correspondence.
 Id. (emphasis added). This response suggests that Mr. Flowers had not changed his view of OST's fee estimate. See also id. ("Since we have gone in circles on this issue, our position is now clear, produce the documents in the FOIA request.").
 Ex. 27 (Email from C. Flowers to K. Simpler and O. Masood dated May 28, 2015 (12:03 PM)).
 Id. We note that FOIA does not permit requesting parties to dictate the time within which a public body must conduct the legal review permitted by the statute, especially where, as here, the request is extraordinarily broad.
 Ex. 30 at 1 (Email from F. Broujos to K. Council dated June 9, 2015 (4:28 PM)). OST also reminded Mr. Flowers that approximately 22,000 emails had been returned in connection with the January 6 Request. Id. OST later accounted for duplicates and revised its tally of the total number of emails returned in connection with both requests. That number is approximately 19,320. Response at 10, 13 n.61.
 Id. at 1-2 (Email from F. Broujos to K. Council dated June 9, 2015 (4:28 PM)).
 Ex. 31 at 1 (Email from K. Council to F. Broujos dated June 9, 2015 (10:25 AM)).
 Ex. 32 at 1 (Letter from P.C. Collins, Jr. to F. Broujos dated July 29, 2015).
 Letter from D. Gibbs to F. Broujos dated August 24, 2015.
 Letter from P.C. Collins, Jr. to D. Gibbs dated August 27, 2015.
 Id. We do not necessarily agree with this argument. Under FOIA, a requesting party is only entitled to obtain access to "public records." In the context of these uniquely broad requests for every email sent and received over a period of four years, we believe that the set may contain emails that do not satisfy the definition (e.g., personal emails, solicitations or announcements from the DSBA). If DTI has filtered all such emails out on the front end, however, Mr. Flowers' argument may be correct.
 Id. at ¶ 1. FOIA does not permit this Office to award attorneys' fees and costs. See 20 Del. C. § 10005(d) ("The court may award attorney fees and costs to a successful plaintiff of any action brought under this section." (emphasis added)). Petitioners may proceed before this Office without retaining counsel, and there are no "costs" associated with presenting a petition to this Office in the sense that the term "costs" is used in the statute. See, e.g., Donovan v. Del. Water & Air Res. Comm'n, 358 A.2d 717, 723 (Del. 1976) ("Costs are allowances in the nature of incidental damages awarded by law to reimburse the prevailing party for expenses necessarily incurred in the assertion of his rights in court." (quotation marks and citation omitted)).
 29 Del. C. § 10001.
 29 Del. C. § 10003(g)(1).
 29 Del. C. § 10003(g)(2).
 29 Del. C. § 10003(m)(2).
 Id. at ¶¶ 28, 31.
 Id. at ¶ 31; 29 Del. C. § 10003(m)(2).
 Del. Op. Att'y Gen. 15-IB03 (June 12, 2015).
 Delaware Freedom of Information Act: Policy Manual for FOIA Coordinators at 6 (July 1, 2015), available at http://attorneygeneral.delaware.gov/documents/FOIA_Manual_10-30-15.pdf (last visited September 26, 2016).
 29 Del. C. § 10003(m)(2) (emphasis added).
 In Del. Op. Att'y Gen. 16-IB09 (Apr. 7, 2016), we concluded that a police department's review of its policy manual to determine, as a matter of fact, which provisions could present a risk to public safety if disclosed, was an administrative review, and "not . . . a legal review to determine if exemptions apply." The opinion made clear that determining whether documents are exempt under FOIA is a "legal review" under the statute, whether the review is conducted by a public body or its counsel. Id.
 Ex. 5 at 3 (Email from L. Gerard to C. Flowers dated February 27, 2015 (2:31 PM)).
 See Del. Op. Att'y Gen. 15-IB03 ("[FOIA] does not, however, prohibit charging for time that staff members spend making any necessary redactions.").
 The statute requires OST to prepare an estimate before reviewing the emails. See 29 Del. C. § 10003(m)(2) ("Prior to fulfilling any request that would require a requesting party to incur administrative fees, the public body shall provide an itemized written cost estimate of such fees to the requesting party, listing all charges expected to be incurred in retrieving such records."). Here, OST prepared its estimate by assuming a two-minute review of each email and multiplying the time by the total number of emails. The total number of minutes was converted to hours, to be charged at a rate of $13.42 per hour, the rate of OST's lowest paid employee. Mr. Flowers has not challenged any aspect of the estimate aside from the charge for legal review, printing fees and photocopying fees.
 OST's counsel has represented that he now believes that the total number of emails responsive to both requests is approximately 19,320. See supra note 95.
 Del. Op. Att'y Gen. 06-IB17 (Aug. 21, 2006).
 Response at 15 ("At this time, however, OST does not have the ability to redact electronically. Accordingly, OST must print all Requested Documents and conduct a manual review and redaction process.").
 See id. at 4 ("Generally, with respect to FOIA requests – and particularly requests for electronic copies, as here – OST's practice under Mr. Flowers' tenure as Treasurer was to print on paper the requested documents, even where citizens requested that they be provided electronically, manually redact non-public information as needed, and then save such documents into a PDF format.") (citation omitted)).
 Indeed, OST states that this is the way FOIA requests were processed during Mr. Flowers' tenure as State Treasurer. See supra note 143.
 Nor do we interpret FOIA to require DTI to purchase or accept an offer by a requesting party to provide specific software. Mr. Flowers offered to purchase software for DTI in order to reduce or eliminate costs which would be imposed for subsequent "narrowed" searches. See Ex. 5 at 3-4 (Email from L. Gerard to C. Flowers dated February 27, 2015 (2:31 PM)). DTI, of course, is not the public body responding to the FOIA request. But even if Mr. Flowers had offered to purchase software for OST, there is no indication that the software would have been compatible with OST's computer systems or that OST would be permitted to install the software under the State's various technology policies. See Response at 9 (stating that "DTI had determined this software was, in fact, not a viable option for the State's IT system"). Fundamentally, however, we do not believe that the statute requires public bodies to make these extraordinary efforts to satisfy any particular FOIA request.
 See id. ("Upon receipt of the estimate, the requesting party may decide whether to proceed with, cancel, or modify the request.").
 See id. at 3. Moreover, OST noted that it would likely offer the same "first review" option to Mr. Flowers in order to reduce his costs. See id.
 Ex. 28 at 3 (Email from C. Flowers to K. Council dated May 9, 2015 (9:01 AM) ("Since we have gone in circles on this issue, our position is now clear, produce the documents in the FOIA request.")).
 Ex. 30 at 1 (Email from F. Broujos to K. Council dated June 9, 2015 (4:28 PM) (indicating that OST was in possession of CDs containing approximately 22,000 emails relating to Mr. Flowers' January 6 Request and 19,000 emails relating to his February 5 Request)).
 See Ex. 32 at 1 (Letter from P.C. Collins, Jr. to F. Broujos dated July 29, 2015) (stating an intention "to propose a reasonable path forward toward amicably resolving this matter").
 Ex. 5 at 3-4 (Email from L. Gerard to C. Flowers dated February 27, 2015 (2:31 PM)). Implicit in this proposal, we believe, was an assumption, which was or became incorrect, but that we believe was reasonable at the time, namely, that Mr. Flowers would not truly want every email ever sent from or received at his state email address to be placed in his archive, and that a good faith review would likely diminish the number of emails OST would be required to review for withholding or redaction.
 We note that the June 9 correspondence from OST's counsel contains language that, when read in isolation, might be interpreted as a demand. In the context of the parties' discussions, however, we believe OST referred only to the "initial review" option in this correspondence because it assumed the parties were not going to reach any agreement on the "traditional" approach without third party intervention. Aside from the clear difference of understanding regarding the meaning of "legal review," the parties disagreed on the issue of whether Mr. Flowers was entitled to receive any category of documents without review by OST or its counsel.
 OST did make the assertion, and it submitted the affidavit of a DTI employee, which stated only that DTI "ran a request" for Mr. Flowers' emails, the employee placed external media containing the requested emails in a sealed envelope at the receptionist's desk and the envelope was picked up. See Ex. 39 (Affidavit of C. Gause dated August 12, 2015). Mr. Flowers submitted no argument relating to the affidavit. See Ex. 32 (Letter from P.C. Collins, Jr. to F. Broujos dated July 29, 2015).
 Id. We have noted our concerns about the propriety of using FOIA for this purpose.
 Petition at ¶ 38. See also, supra, fact section discussion related to notes 97-100.
 See Ex. 30 at 2 (Email from F. Broujos to K. Council dated June 9, 2015 (4:28 PM)).
 See Ex. 1 at 3 (Email from C. Flowers to O. Masood dated February 3, 2015 (1:20 PM) ("I am assuming the [Attorney General's] office will be conducting the legal review, so the internal estimate should not be that much.")); Ex. 5 at 4 (Email from C. Flowers to O. Masood dated February 26, 2015 (12:00 PM) ("Further, any emails and documents relating to legal privilege (where a AG office member was copied) would need to be reviewed by the Attorney General's office for such determination as to whether the privilege was mine (which means the email and attached document could be disclosed) or the privilege belonged to the state and no charge would be attributed to me for such review as there is no charge for legal review by the Attorney General's Office.").
 See Del. Op. Att'y Gen.15-IB03 ("We do not believe that the General Assembly views FOIA as a profit-making opportunity for public bodies, nor that it would countenance the use of a high fee estimate as a device to discourage a citizen from pursuing a request.").
 Petition at ¶ 42. Mr. Flowers does not cite to any evidence in the record to support the claims in this paragraph.


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