1. Levels or limitations on fees.

Under ORS 192.440(4)(a) a fee "reasonably calculated to reimburse" the public body for its actual cost in making the records available may be charged. No more than the actual cost may be charged by a public body. 39 Op. Atty Gen. 721 (1979). In Defense of Animals v. OHSU, 199 Or. App. 160, 112 P.3d 336 (2005). The records custodian has the burden of demonstrating the reasonableness of charges for "actual costs" and must do so with specific supporting data. If such data is absent, the charges are per se not reasonable. In Defense of Animals; Davis v. Walker, 108 Or. App. 128, 814 P.2d 547 (1991). If the fee will exceed $25, a public body must first provide an estimate of the fee and confirm that the requester wants to proceed. ORS 192.440(4)(c).