EMAIL: Lots and lots of email records. Even narrow requests can generate lots of emails. Increase the date range or number of people or keywords and you're talking beaucoup records.
WIDE RANGING REQUESTS: FOIA doesn't require a request to be narrow, but broader requests are going to yield more records and those records have to be reviewed.
HIGHLY PAID EMPLOYEES: Lawyers, administrators and IT professionals tend to make more money and they get to charge their hourly rate when they're involved in the FOIA process.
EXCLUSION REVIEW: Exclusion review is the time it takes to review a record to see if it can or must be withheld. More records mean more time --> Attorneys who have a higher hourly rate often do exclusion review --> higher fee estimate. In American Tradition Institute v. University of Virginia, the Supreme Court of Virginia ruled in 2014 that, “In the context of Code § 2.2-3704(F), ‘searching’ includes ‘inquiring or scrutinizing’ whether a disputed document can be released under federal and state law. Therefore, the ordinary meaning of ‘searching’ in this statutory provision permits a public body to charge a reasonable fee for exclusion review."
FOIA OFFICERS CHARGE FOR THEIR TIME: Even though the job is required by statute, some FOIA officers charge for the time they spend filling FOIA requests.
SMALL STAFFS: Especially in small localities, lots of employees are wearing lots of different hats. For them, the time they spend on FOIA/any other duty takes away from any other duty/FOIA.
BUDGET CRUNCHES: State mandates, overtaxed citizens, money-wasting projects? All can contribute to government office budgets that cannot sustain fully funded FOIA officers or the purchase of helpful FOIA-fulfilment software.
POOR RECORD KEEPING: Disorganized records. Important records already in storage. Retention schedules not followed. The longer it takes to find the record, the more time spent searching and that time gets billed to the requester.
UNCLEAR PROCESSES: Do all employees know who handles FOIA requests? Does the FOIA officer have the authority to leverage other employees to participate in filling a request? Confusion can lead to inefficient processing.
INCONSISTENCY: Policies can vary from one locality, police department, school district, university or state agency to the next. That's partly because the "actual cost" will be different for each, but it's also because they each have different processes and those processes are often not made known to requesters.
BAD ACTORS: They may be stereotypes, but they're based in truth. There are public bodies that use FOIA fees to deter requests. There are requesters that use FOIA as a sword to bring government to a standstill.