A laudable panel. Congratulations.
I just wanted to note that you probably intended your first bullet point to read the “establishment of the presumption of openness standard” rather than the “established of . . . .” To quibble, it could be said that the Act has always contained such a presumption, inasmuch it requires the release of records unless the government proves that an exemption applies.
To quibble further, the “release once, release to all” program might be more accurately described as a proactive disclosure program rather than a “presumption.”