Fees are a never-ending struggle between government and records requesters. Virginia FOIA says: government can “make reasonable charges not to exceed its actual cost incurred in accessing, duplicating, supplying, or searching for the requested records.”
The Virginia Supreme Court just confirmed that government can charge for the time it takes to review -- and, by implication, redact and decide that a record is exempt -- so now there’s a little more guidance (for better or for worse) on when a charge for labor can be imposed.