—I dissent.
To support its holding that a governor’s appointment calendars and schedules are exempt from disclosure, the majority relies primarily on the deliberative process privilege. Because the requested documents reveal the identity of those with whom a governor has met, the majority reasons that their disclosure would reveal “the substance or direction of the Governor’s judgment and mental processes” (maj. opn., ante, p. 1343) or “devalue or eliminate altogether a particular viewpoint from the Governor’s consideration” (maj. opn. ante, p. 1344) and thereby “chill the flow of information to the executive office” (maj. opn., ante, p. 1345). I am not persuaded.
The documents at issue disclose only the fact of meetings, not the contents of communications. With rare exceptions, the deliberative process is not compromised by disclosing merely the identity of the participants in policy discussions. Even assuming that the documents at issue contain some material protected by the deliberative process privilege, the government has not made the detailed and specific showing required to establish such a claim, and such protected matter, if it exists, could be easily segregated *1350from the bulk of the requested public records.1 I conclude also that concerns about a governor’s security do not warrant complete exemption of the requested records.
I
The California Public Records Act (Gov. Code, § 6250 et seq.; hereafter the Act)2 was modeled on the federal Freedom of Information Act (5 U.S.C. § 552; hereafter the FOIA). The purpose of both the Act and the FOIA is to require that public business be conducted “under the hard light of full public scrutiny” (Tennessean Newspapers, Inc. v. Federal Housing Admin. (6th Cir. 1972) 464 F.2d 657, 660), and thereby “to permit the public to decide for itselfwhether government action is proper” (Washington Post Co. v. U S. Dept, of Health, etc. (D.C. Cir. 1982) 690 F.2d 252, 264, italics in original). The Act declares that “access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person in this state.” (§ 6250.) For both the FOIA and the Act, “disclosure, not secrecy, is the dominant objective.” (Dept, of Air Force v. Rose (1976) 425 U.S. 352, 361 [48 L.Ed.2d 11, 21, 96 S.Ct. 1592].)
Because the FOIA provided a model for the Act, and because they have a common purpose, the Act and its federal counterpart “should receive a parallel construction.” (American Civil Liberties Union Foundation v. Deukmejian (1982) 32 Cal.3d 440, 451 [186 Cal.Rptr. 235, 651 P.2d 822].) Therefore, federal decisions under the FOIA may be used to construe the Act. (Braun v. City of Taft (1984) 154 Cal.App.3d 332, 342 [201 Cal.Rptr. 654]; San Gabriel Tribune v. Superior Court (1983) 143 Cal.App.3d 762, 772, 111 [192 Cal.Rptr. 415].)
It is undisputed that the Act protects the deliberative processes of government agencies and officials, but it is not clear whether it does so through subdivisions (a) or (k) of section 6254 (see maj. opn., ante, p. 1339, fns. 8 & *13519), through section 6255, or through all of these. (See 53 Ops.Cal.Atty.Gen. 136 (1970).) The majority proceeds on the assumption that the Act protects the deliberative process through section 6255.3 Although it would seem that the deliberative process privilege is more properly located in subdivision (a) of section 6254 (see Citizens for a Better Environment v. Department of Food & Agriculture (1985) 171 Cal.App.3d 704, 712 [217 Cal.Rptr. 504]), I will likewise assume, for purposes of this case only, that it may properly be asserted under section 6255.
The role of the deliberative process privilege under the FOIA has been well defined. The privilege is included within the ambit of what is commonly referred to in FOIA cases as exemption 5.4 (See EPA v. Mink, supra, 410 U.S. 73, 85-86 [35 L.Ed.2d 119, 131-132].) Because the deliberative process privilege has been the subject of intense and careful scrutiny in the context of the FOIA, consideration of the cases and commentaries construing the federal legislation is crucial to a proper resolution of the issue presented here.
The deliberative process privilege protects an agency’s internal working papers consisting of advice, recommendations, opinions, and other material reflecting deliberative or policymaking processes. (Wu v. National Endowment for Humanities (5th Cir. 1972) 460 F.2d 1030, 1034; Soucie v. David (D.C. Cir. 1971) 448 F.2d 1067, 1077 [145 App.D.C. 144].) Like all exemptions under both the FOIA and the Act (see United States Dept, of Justice v. Julian, supra, 486 U.S. 1, 8 [100 L.Ed.2d 1, 11]; New York Times Co. v. Superior Court (1990) 218 Cal.App.3d 1579, 1585 [268 Cal.Rptr. 21]), it is to be narrowly construed.
The privilege has three policy bases: “First, it protects creative debate and candid consideration of alternatives within an agency, and, thereby, *1352improves the quality of agency policy decisions. Second, it protects the public from the confusion that would result from premature exposure to discussions occurring before the policies affecting it had actually been settled upon. And third, it protects the integrity of the decision-making process itself by confirming that ‘officials should be judged by what they decided^] not for matters they considered before making up their minds.’ ” (Jordan v. United States Dept, of Justice (D.C. Cir. 1978) 591 F.2d 753, 772-773 [192 App.D.C. 144], fns. omitted.) The ultimate purpose of the deliberative process privilege is “to prevent injury to the quality of agency decisions.” (NLRB v. Sears, Roebuck & Co. (1975) 421 U.S. 132, 151 [44 L.Ed.2d 29, 47, 95 S.Ct. 1504].)
To qualify for exemption under the deliberative process privilege, a document or a portion of a document must be both predecisional and deliberative. (NLRB v. Sears, Roebuck & Co., supra, 421 U.S. 132, 151-154 [44 L.Ed.2d 29, 47-49]; Mead Data Cent., Inc. v. U. S. Dept, of Air Force (D.C. Cir. 1977) 566 F.2d 242, 257 [184 App.D.C. 350].) To establish that a document is predecisional, an agency must identify an agency decision or policy to which the document contributed (Senate of Puerto Rico v. U.S. Dept, of Justice (D.C. Cir. 1987) 823 F.2d 574, 585 [262 App.D.C. 166]), or at least must show “that the document is in fact part of some deliberative process” (1 Braverman & Chetwynd, Information Law (1985) § 9-4.3.1, p. 364, italics in original; NLRB v. Sears, Roebuck & Co., supra, 421 U.S. at p. 151, fn. 18 [44 L.Ed.2d at p. 48]).
In this case, the government has satisfied neither of these foundational requirements for invoking the deliberative process privilege.
First, the government has not shown that the documents are predecisional. It has not identified particular policies or decisions that resulted from particular meetings mentioned in the calendars and schedules or otherwise shown that the meetings were each part of some deliberative process. Indeed, it seems likely that many of the meetings were ceremonial occasions unrelated to any policy or decision, and that others consisted of explanation of policies already formulated or the formulation of plans and strategies for their implementation. The deliberative process privilege can have no application to such postdecisional or nondecisional meetings.
Second, the government has not shown that the documents are deliberative. To qualify as deliberative, a document generally must consist of opinions or recommendations. Purely factual material may be withheld only if it is “inextricably intertwined with policy-making processes” (Soucie v. David, supra, 448 F.2d 1067, 1077-1078, fn. omitted), if it would expose the deliberative process by the manner in which the factual material is *1353organized or presented (Ryan v. Department of Justice (D.C. Cir. 1980) 617 F.2d 781, 790 [199 App.D.C. 199]), or if it would compromise the agency’s ability to gather information in the future (Brockway v. Department of Air Force (8th Cir. 1975) 518 F.2d 1184, 1191-1192).
The majority relies on an analogy between agency summaries of factual material, which are exempt from disclosure if they reveal the deliberative process by the manner in which material is summarized, and appointment calendars showing the persons with whom a high government official has met. The majority encapsulates this reasoning in the following sentence: “Disclosing the identity of persons with whom the Governor has met and consulted is the functional equivalent of revealing the substance and direction of the Governor’s judgment and mental processes; such information would indicate which interests or individuals he deemed to be of significance with respect to critical issues of the moment.” (Maj. opn., ante, p. 1343.)
The analogy is inapt. The selection of a fact for inclusion in a summary indicates clearly and directly that the person making the summary considers it important to the decision. But information that a governor has met or will meet with an individual on a particular date has no such unambiguous significance. Although disclosure of appointment calendars and schedules does provide glimpses into the inner workings of the governor’s office, and thereby serves a substantial public interest, these glimpses are so indirect that they will injure the decisional process only in rare instances.
Consider first a list of the occasions on which a governor has met or will meet with members of his or her personal staff or with the heads of executive branch agencies. Without information as to both the topics discussed and the advice or opinions offered, such a list would reveal nothing about the status of the governor’s thinking about “critical issues of the moment.” Although information that a governor seldom or never meets with an agency director could signify that the governor has little confidence in the individual’s advice (it could also indicate a preference for communication by telephone or written memorandum), it would disclose nothing about the substance of the governor’s thinking on any issue and so would pose no threat of injury to the deliberative process.
Consider next a list of occasions on which a governor has met with persons outside state government. Although the list would not disclose the topics discussed or the advice or opinions expressed, these could sometimes be inferred if the persons with whom the governor met had publicly advocated particular positions on issues that required a decision by the governor. Even in these cases, however, information that the governor met with an *1354advocate for a particular position reveals little about how the governor is inclined to decide the issue. Governors do not meet only with advocates whose views they are inclined to favor. A governor may wish to test a tentative decision or inclination against the arguments of those advocating a different course, or the governor may choose to hear the opposing arguments as a matter of courtesy, political expediency, or public relations. And if a governor has met with representatives of all points of view, what can this possibly reveal about “the substance and direction of the Governor’s judgment” as to the question at issue? Thus, information that a governor has met with an individual does not reveal the governor’s judgment about the merits of the position the individual is advocating, and so poses no discernible threat of injury to the deliberative process.
On the other hand, there is a very substantial public interest in disclosure of the occasions on which a governor has met with persons outside government who seek to influence the governor’s decisions on critical issues. This interest is reflected in the many decisions under the FOIA holding that the deliberative process privilege does not protect communications by interested parties seeking to influence government decisions. (Van Bourg, Allen, Weinberg & Roger v. N.L.R.B. (9th Cir. 1985) 751 F.2d 982, 985; County of Madison, N. Y. v. U S. Dept, of Justice (1st Cir. 1981) 641 F.2d 1036, 1040-1042; Mead Data Cent., Inc. v. U. S. Dept, of Air Force, supra, 566 F.2d 242, 257-258; NAACP Legal Defense Fund v. U.S. Dept, of Justice (D.D.C. 1985) 612 F.Supp. 1143, 1146-1147; see also Weaver & Jones, The Deliberative Process Privilege (1989) 54 Mo.L.Rev. 279, 300; Project: Government Information and the Rights of Citizens (1975) 73 Mich.L.Rev. 971, 1071; Note, The Freedom of Information Act: A Seven-year Assessment (1974) 74 Colum.L.Rev. 895, 942; Note, The Freedom of Information Act and the Exemption for Intra-agency Memoranda (1973) 86 Harv.L.Rev. 1047, 1065.) The public interest in monitoring the activities of those who seek to gain private advantage by influencing government decisions is also reflected in the detailed regulatory system enacted to control the practice of lobbying. (§ 86100 et seq.)
Although the majority defends its holding with citation to Brockway v. Department of Air Force, supra, 518 F.2d 1184, examination of that decision exposes the weakness of the majority’s position. The Brockway court held that the deliberative process privilege protects an agency document containing the statements of witnesses to an airplane crash. Yet in that case the agency voluntarily revealed the names of the witnesses it had interviewed. (Id. at p. 1186.) No claim was ever made that disclosing merely the fact of the interviews, as opposed to what was said, would harm the deliberative *1355process privilege.5 (See also 8 Wright & Miller, Federal Practice and Procedure (1970) § 2019, pp. 160-161 [“Frequently statutes requiring particular kinds of reports to be made to government will provide that such reports are to be kept confidential. . . . The fact that a person has made a report of this kind is not privileged, even though the contents of the report may be.”].)
Many other FOIA decisions also weigh heavily against the majority’s conclusion. Under the FOIA, courts and commentators alike have concluded that the identities of persons who participate in the process of formulating policy within a governmental agency by giving opinions, advice, or recommendations are essentially factual rather than deliberative, and that disclosure of documents revealing the names of participants in policy formulation will not compromise the deliberative process.
For instance, in two cases in which it was alleged that the government had charged exorbitant prices for homes sold to low-income buyers, courts ordered disclosure of the identity of the appraisers on whom the government had relied. (Tennessean Newspapers, Inc. v. Federal Housing Admin., supra, 464 F.2d 657; Philadelphia Newspapers, Inc. v. Department of H. & U. D. (E.D.Pa. 1972) 343 F.Supp. 1176.) One of these courts observed that the appraisers’ names were outside the deliberative process privilege because names are “essentially factual.” (Philadelphia Newspapers, Inc. v. Department of H. & U. D., supra, at p. 1178.) The other court, recognizing the public’s interest in disclosure of conflicts of interest, remarked that the “name of an appraiser could be sufficient to establish a motivation sufficient to trigger an investigation.” (Tennessean Newspapers, Inc. v. Federal Housing Admin., supra, at p. 660.)
In another case, a federal district court ordered the Federal Trade Commission to disclose the names of outside experts it had consulted during the process of formulating a regulation. The court stated: “The government has attempted to expand the policy of exemption 5—encouragement of a frank discussion of legal and policy matters in order to enhance the quality of agency decisions—beyond its necessary and proper limits. The FOIA *1356‘creates a liberal disclosure requirement, limited only by specific exemptions which are to be narrowly construed.’ [Citation.] Outside expert consultants would not be chilled in their advice or recommendations to the agency if it were known that they had rendered advice. After all, as experts they are members of a profession v/hich demands the rendition of advice to many groups. They should expect the fact of rendition to eventually become public. Protection of the content of the advice rendered would adequately serve the purpose of encouraging frank discussion, and therefore the names and addresses of the outside expert consultants will be ordered disclosed.” (Assn, of National Advertisers, Inc. v. FTC (D.D.C. 1976) C.A.No. 75-1304, 1976-2 Trade Cas. (CCH) 61,021, pp. 69,491, 69,493; see also Assn, of National Advertisers, Inc. v. FTC (D.D.C. 1976) C.A.No. 75-0896, 1976-2 Trade Cas. (CCH) 61,112, pp. 70,041, 70,045.)
Commentators have reached the same conclusion: “A requirement that names be disclosed is supported in the most mechanical sense by the observation that names are factual and that factual material falls outside the ambit of the exemption’s protection. More importantly, the same kind of policy analysis that underlies the factual material limitation of exemption (5) argues for disclosure of names. Few outside consultants would be discouraged from providing recommendations by the mere prospect that their names would be disclosed, without the content of their advice; indeed, the most likely cases for such discouragement are those of blatantly prejudiced potential consultants who would fear the public imputation of malice. And there is of course a public interest in knowing who is being consulted by the Government and contributing to its decisions.” (Note, The Freedom of Information Act and the Exemption for Intra-agency Memoranda, supra, 86 Harv.L.Rev. 1047, 1065-1066, fn. omitted; see also O’Reilly, Federal Information Disclosure (1989) § 15.16, pp. 15-78 to 15-79.)
Disclosure of the identity of participants in policy formulation occurs routinely in FOIA cases. Often, the agency has made the disclosure voluntarily. (See, e.g., Washington Post Co. v. U. S. Dept, of Heath, etc., supra, 690 F.2d 252, 257.) In other cases, the trial court has mandated disclosure by requiring the agency to prepare a Vaughn index (named after Vaughn v. Rosen (D.C. Cir. 1973) 484 F.2d 820 [157 App.D.C. 340]), and to furnish the index to both the court and the requesting party.
A Vaughn index identifies the author, recipient, and subject matter of each document that the agency has withheld in whole or in part under a claim of exemption, (see Osborn v. I.R.S. (6th Cir. 1985) 754 F.2d 195, 196; Weaver & Jones, op. cit. supra, 54 Mo.L.Rev. 279, 301-302.) The purpose of the index is to give the court and the opposing party sufficient information about the withheld document, or portion of a document, to assess the *1357validity of the agency’s exemption claim. (Vaughn v. Rosen, supra, 484 F.2d 820.) The government must provide a Vaughn index before the court makes its decision “in most FOIA cases.” {Osborn v. I.R.S., supra, at p. 197.)
Although the participants in the process of policy formulation and rule-making are disclosed through the Vaughn indexes, this has not prevented the courts from making them a standard procedure in FOIA cases. Rather, the federal courts’ continued use of the Vaughn index implies a determination that disclosing the names of agency employees who have authored internal documents, the contents of which are or may be privileged, will work no harm to an agency’s deliberative process in the vast majority of cases. (See 1 Braverman & Chetwynd, op. cit. supra, § 9-4.S.2, at p. 371.)6
Because the schedules and calendars at issue disclose only the identity of persons who have met with the Governor, and not what was said at those meetings, the deliberative process privilege can have little, if any, application. The frank exchange of views is unlikely to be compromised by public knowledge of the occasions on which a governor has met in the past with other government officials, with particular members of the governor’s personal staff, or with persons outside state government. The majority holding, under which documents containing the names of persons who might have participated in policy formulation may be withheld from the public, finds no support in the deliberative process privilege.
II
The majority also relies to some extent on concern for a governor’s physical safety. The government submitted evidence in the trial court that disclosure of former Governor Deukmejian’s appointment calendars and schedules would have revealed his characteristic patterns of movement while in office and would have disclosed particular times when he would likely have been alone. The government argues that this information could be useful to a potential assailant, and that it therefore should be kept confidential.
This argument should be rejected. The government has not shown that disclosure of appointment calendars and schedules would elevate the risk above that which high public officials normally must accept. For example, *1358those elected to the Legislature must attend its public sessions, as judges must attend the public sessions of court. Although such public appearances, at preannounced times and places, carry a certain risk to the safety of legislators and judges, the risk is one that is deemed acceptable.7 Greater safety for public officials might be obtainable at the cost of total secrecy in government, but the price would be unacceptably high.
Ill
The government may be able to establish that parts of a governor’s appointment calendars and schedules are exempt from disclosure under the Act, even though it has not established an exemption for these public records as a whole.
The public official or agency invoking an exemption bears the burden of establishing that it applies. (§ 6255; Senate of Puerto Rico v. U.S. Dept, of Justice, supra, 823 F.2d 574, 585; Church of Scientology, etc. v. U. S. Dept. (9th Cir. 1979) 611 F.2d 738, 742; Braun v. City of Taft, supra, 154 Cal.App.3d 332, 345.) To discharge its burden, an agency may not rely upon conclusory and generalized allegations. (Senate of Puerto Rico v. U.S. Dept, of Justice, supra, at p. 585; Church of Scientology, etc. v. U S. Dept., supra, at p. 742.) Instead, it must provide a “detailed factual justification” for each exemption claim (Washington Post Co. v. U S. Dept, of Health, etc., supra, 690 F.2d 252, 269; see also Mead Data Cent., Inc. v. U S. Dept, of Air Force, supra, 566 F.2d 242, 258 [an agency “must show by specific and detailed proof that disclosure would defeat, rather than further, the purpose of the FOIA”]; Black v. Sheraton Corporation of America (D.D.C. 1974) 371 F.Supp. 97, 101 [“To recognize such a broad claim [of privilege,] in which the [government] has given no precise or compelling reasons to shield these documents from outside scrutiny, would make a farce of the whole procedure.”].)
Although a heavy burden is thus imposed on a public official or agency seeking to avoid disclosure, the burden is not impossible to discharge. In this case, there may well be portions of the appointment calendars and schedules at issue that are protected by the deliberative process privilege, by the interest in protecting the Governor’s safety, or by other important *1359public interests. For this reason, I agree with the Court of Appeal that the case should be remanded to give the government an opportunity to provide the detailed factual justification required to establish that portions of the schedules and calendars are exempt from disclosure. If a factual dispute remained after a sufficiently detailed justification had been provided, the proper procedure would have been for the trial court to conduct an in camera review of the documents, or at least of a representative sample. (See EPA v. Mink, supra, 410 U.S. 73, 93 [35 L.Ed.2d 119, 135]; Church of Scientology, etc. v. U. S. Dept., supra, 611 F.2d 738, 742.)
When the government succeeds in establishing that parts of requested documents are exempt, those portions are deleted and the rest disclosed. This is mandated by section 6257, which provides: “Any reasonably segregable portion of a record shall be provided to any person requesting such record after deletion of the portions which are exempt by law.” (See also Johnson v. Winter (1982) 127 Cal.App.3d 435, 440 [179 Cal.Rptr. 585]; Anderson v. Department of Health & Human Services (10th Cir. 1990) 907 F.2d 936, 941.)
IV
A former United States Attorney General has remarked: “Nothing would be so alien to our form of government as pervasive secrecy, for people cannot govern themselves if they cannot know the actions of their government. Yet it is elementary that the welfare of the nation and that of its citizens may require that some information be kept in confidence.” (Richardson, Freedom of Information (1974) 20 Loyola L. Rev. 45.) The FOIA and the Act seek to accommodate these competing concerns by mandating a general policy of full disclosure, with specific and narrowly drawn exemptions.
To establish an exemption under section 6255, an agency must show “that on the facts of the particular case the public interest served by not making the record public clearly outweighs the public interest served by disclosure of the record.” (Italics added.) When conducting this balancing process, the public’s right to know what public officials are doing8 provides “a heavy and constant weight” in favor of disclosure. (Comment, The California Public Records Act: The Public's Right of Access to Governmental Information (1976) 7 Pacific LJ. 105, 119; see also Citizens for a Better Environment v. Department of Food & Agriculture, supra, 171 Cal.App.3d *1360704, 715 [“If the records sought pertain to the conduct of the people’s business there is a public interest in disclosure.”].) The weight varies, however, in accordance with “the gravity of the governmental tasks sought to be illuminated and the directness with which the disclosure will serve to illuminate.” (Citizens for a Better Environment v. Department of Food & Agriculture, supra, at p. 715.) How our state governors spend their working hours, and how they go about obtaining advice and formulating policy are matters of great public importance, and, as already noted, disclosure of the names of the persons with whom a governor has met during office hours will illuminate this subject in significant ways.
The public interest in secrecy has not been shown to clearly outweigh this interest in disclosure. The government has made no specific and detailed demonstration that the requested documents, and all reasonably segregable portions of those documents, must be withheld to protect the deliberative processes or the physical safety of our state governors. By holding that the public has no right to know the identity of persons with whom a governor has met, the majority expands the deliberative process privilege well beyond its proper ambit and disregards the wisdom of the federal courts and legal commentators. I would hold that neither the deliberative process privilege, nor concern for the physical safety of our governors, nor the two combined, justifies a blanket exemption for a governor’s personal appointment calendars and schedules. I therefore would affirm the judgment of the Court of Appeal.
Broussard, J., concurred.
It bears emphasis that a governor’s appointment calendars and schedules are indeed public records. The government has conceded as much in this case, and courts have so held in regard to similar documents prepared for executive branch officials (Washington Post v. U.S. Dept, of State (D.D.C. 1986) 632 F.Supp. 607 [records of schedule of Secretary of State Alexander Haig]; Bureau of Nat. Affairs v. U.S. Dept, of Justice (D.D.C. 1984) 742 F.2d 1484, 1495 [239 App.D.C. 331] [daily agendas of Assistant Attorney General William Baxter]; Kerr v. Koch (N.Y. 1988) 15 Media L.Rptr. 1579 [appointment calendar of New York City mayor]).
As the majority points out (maj. opn., ante, p. 1342, fn. 12), in one of these cases the court remarked that its decision “does not limit the defendant’s right to withhold portions of the documents under a valid claim of statutory exemption pursuant to the Act.” {Washington Post v. U.S. Dept, of State, supra, 632 F.Supp. 607, 616, italics added.) None of the cases in any way suggests that calendars and schedules might be entirely exempt from disclosure.
All further statutory references are to the Government Code, unless otherwise stated.
Section 6255 contains a residuary or “catchall” exemption. It provides: “The agency shall justify withholding any record by demonstrating that the record in question is exempt under express provisions of this chapter or that on the facts of the particular case the public interest served by not making the record public clearly outweighs the public interest served by disclosure of the record.” (Italics added.) Note that this public interest exemption applies to individual records, rather than to entire classes of records.
Exemption 5, which the United States Supreme Court has termed a “somewhat Delphic provision” (United States Dept, of Justice v. Julian (1988) 486 U.S. 1, 11 [100 L.Ed.2d 1, 13, 108 S.Ct. 1606]), permits an agency to withhold from disclosure “inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency.” (5 U.S.C. § 552(b)(5).) It was intended to incorporate the substance of certain privileges, including the deliberative process privilege, that would be available to the government during litigation to shield internal agency documents. (See United States v. Weber Aircraft Corp. (1984) 465 U.S. 792 [79 L.Ed.2d 814, 104 S.Ct. 1488].) The high court has cautioned, however, that discovery rules should be applied to FOIA cases only “by way of rough analogies.” (EPA v. Mink (1973) 410 U.S. 73, 86 [35 L.Ed.2d 119, 131, 93 S.Ct. 827].)
Moreover, it seems unlikely that a governor’s meetings would involve the kind of factual investigation at issue in Brockway, supra, 518 F.2d 1184, as such investigations are normally conducted at lower levels of the executive branch. If a governor did meet in confidence with an individual to acquire information, and disclosure of the meeting could jeopardize a governor’s ability to acquire similar confidential information in the future, a claim of privilege should be recognized. (See 53 Ops.Cal.Atty.Gen., supra, 136, 149 [“The need of a governmental agency to preserve its informational input channels has been recognized by the courts and the Legislature in this State as vital to the efficient operation of government.”].) But such instances must be quite rare, and the government bears the burden of identifying them to the extent they exist within the requested material, as discussed below in part III of this dissent.
There are specific exceptions to this general rule of disclosure. For example, it has twice been held that the identity of persons who rendered advice need not be disclosed when the content of their advice has already been made public and disclosure could discourage candid advice in the future. (Tax Reform Research Group v. I.R.S. (D.D.C. 1976) 419 F.Supp. 415, 423-424; Wu v. Keeney (D.D.C. 1974) 384 F.Supp. 1161, 1166.) Here, the government has not made the showing required to establish any such exception.
The schedules apparently contain detailed information about airport gate departures and arrivals, means of ground transportation, hotel accommodations, and the like. This level of detail may well elevate the risk above that which high government officials normally must accept, but the briefs of the requesting party reveal that it does not now seek such information and it could be deleted from the documents before disclosure. The essence of the request is for documents revealing the identity of the persons with whom former Governor Deukmejian met and the dates and times of the meetings.
The clearest and most emphatic expression of this right appears in section 54950: “The people, in delegating authority, do not give their public servants the right to decide what is good for the people to know and what is not good for them to know. The people insist on remaining informed so that they may retain control over the instruments they have created.”