As used in this paragraph, the terms memoranda, reports, statements, opinions, files, and papers do not generally include interagency or intra-agency materials, except those that are statistical or factual tabulations or data, instructions to staff that affect the public, or final agency policy or determinations. Discussions of policy options and recommendations are not statistical or factual tabulations, and are not included in the definition of records.
N.Y. Comp. Codes R. & Regs. Tit. 9 §§ 145-1.1