What about old requests?

The Justice Department’s Office of Information Policy, which oversees FOIA operations among the agencies, has directed agencies to apply the new standards going forward. For requests that have already received a response, a requester can return to the agency without initiating an administrative appeal to ask the agency to reconsider the request in light of the new guidelines — without filing a new request.

Agencies can either treat the request as “re-opened” and re-evaluate it presently, or the agency can treat it as a new request and put it at the end of the queue. However, requesters should keep in mind the agency’s appeal clock so that right is not lost altogether.