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disclosure. Compare, RCW 29A.60.230, providing a special
protection for aggregating public election results when the number
of voters is so low in a precinct that separate reporting of precinct
results may reveal identity).
We agree with the trial court's reasoning. Redaction will not eliminate the
risk that disclosing copies of ballots will reveal the identity of individual voters.
Ballots are exempt in their entirety.
ADEQUACY OF COUNTY RESPONSES
White argues that even ifthe ballot images are exempt, he is entitled to an
award of attorney fees and a daily penalty under the Public Records Act because
the counties' responses were insufficient.
Agency responses refusing inspection of any public record must include a
statement of the specific exemption authorizing the withholding of the record and
"a brief explanation" of how the exemption applies to the record withheld. RCW
42.56.210(3). In order to satisfy the exemption requirements, the public agency
must identity the specified record, cite statutory exemptions, and briefly explain
how the exemptions apply to the requested records. PAWS, 125 Wn.2d at 271
n.18. Claims of exemption should contain enough details to (1) enable a
requestor to make a threshold decision about whether the exemption was proper
and (2) enable judicial review of the decision to withhold. Rental Hous. Ass'n of
Puget Sound v. City of Pes Moines. 165 Wn.2d 525, 540-41, 199 P.3d 393
(2009); Sanders v. State, 169 Wn.2d 827, 845-49, 240 P.3d 120 (2010).
Skagit County provided White with a 2,111-page exemption log. The log
listed each ballot withheld by its serial number and gave, for each, the same brief
explanation.