deference, we concluded, the Commonwealth Court had erected a barrier to disclosure that was “irreconcilable with the RTKL.” We held that the court had abused its discretion by declining to conduct in camera review “simply because there [was] no facial evidence of bad faith.” 12 This Court vacated the Commonwealth Court’s order and remanded the case for further proceedings. Following remand, the Commonwealth Court proceeded to conduct an in camera review of the unredacted version of AR 6-9. 13 The court determined that the text of each section and the description and statements in the affidavit concerning the risks arising from disclosure [were] insufficient to allow [it] to determine whether disclosure . . . could reasonably be expected to aid criminals in evading detection of illegal activities or [with respect to some sections,] to aid unacceptable candidates in hiding unfavorable background information. 14 The Commonwealth Court repeatedly found that it could not “determine from the current record whether disclosure of this section would be reasonably likely to threaten public safety or preparedness.” 15 The court recognized that, in general, “it is the burden of the party resisting disclosure to establish that an exemption from the RTKL applies.” 16 It opined, however, that, “where the subject matter of a request involves public safety or security, such as in police matters, careful consideration of a complete record is especially important, and supplementation of the record, if necessary, is appropriate.”17 12 Id. Pa. State Police v. ACLU of Pa., 1066 C.D. 2017, 2021 WL 5356532, at *2 (Pa. Cmwlth. Nov. 17, 2021) (“PSP III”). 13 14 Id. at *2-*4. 15 Id. 16 Id. at *4 (citing Pa. State Police v. Muller, 124 A.3d 761, 766 (Pa. Cmwlth. 2015)). 17 Id. [J-3-2023] - 4