Participated in comments (with the Reporters Committee and other media groups) filed with the U.S. Office of Management and Budget regarding proposed changes to OMB’s “Guidelines” on FOIA fees. The proposed updates (prompted by a recent lawsuit) are limited to a small number of issues. These comments address two issues: (1) the elimination of a definition of “representative of the news media,” and (2) the addition of a statement that the Guidelines do not address the reduction or waiver of fees under FOIA (which, in fact, they do). OMB says that a definition of news media representative is no longer necessary because it was codified in FOIA’s 2007 amendments. However, it is important that OMB include the statutory standard as well as the D.C. Circuit’s broad interpretation of who qualifies as a representative of a news media outlet.