ELR Citation: 56 ELR 20011
No(s). 25-12249-WGY (D. Mass. Jan 23, 2026) (Young, J.)

A district court granted in part and denied in part nonprofit groups' motion to compel disclosure of Federal Advisory Committee Act (FACA) records relating to DOE's formation of an advisory committee that developed a report on the climate impacts of greenhouse gas emissions. The groups argued that emails authored by members of the committee were partially withheld in improper reliance on FOIA Exemption 6. DOE argued the personal information of the reviewers of the report were properly withheld under the exemption. The court found the privacy interest in non-disclosure only of names was not substantial and that there was no evidence that physical, reputational, or financial harm would befall the reviewers. It also found that the public interest in the FACA context warranted greater disclosure than in the ordinary FOIA context, and that the various factors committee members considered in drafting represented a compelling public interest because the public lacked the opportunity to participate in the process before the report was published. It ordered the emails authored by committee members to be disclosed in their entirety, with names of the reviewers of the draft report disclosed, but that the reviewers' personal information may properly continue to be withheld.