Home » Commentary » Patrice McDermott posts Draft letter re DOI records disposition request to NARA. Requests comments

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Patrice McDermott posts Draft letter re DOI records disposition request to NARA. Requests comments

We posted about the Dept of Interior records schedule request to NARA and have been actively working on this issue for a few weeks now. Patrice McDermott, Director of Government Information Watch — many of you will have known Patrice from her ALA Washington Office days or laster as director of Open The Government — just posted the request below to govdoc-l so I thought I’d share beyond the govt documents library community. Please check out the draft letter that Patrice and several others in the FOIA/open govt communities have penned. Send any comments or concerns her way. And if you’d like to copy/paste anything from her letter — or from Stanford UL’s letter to AOTUS Ferriero for that matter — for your own comment to NARA, please do so BY NOVEMBER 26!

Here is a DRAFT letter/comments to NARA. Many thanks to the folks who have been working on this – this letter draws heavily on your work.

Thoughts, edits – and specific concerns about particular sets of records – welcomed. Please send to me pmcdermott@govinfowatch.net.

It dawned on me that T’giving week is almost upon us… I plan to send this Friday 23 November. It is open to both organizational and individual signatories.


As you may know, the DOI has put in a request to NARA for disposition authority for a large # of record groups. Disposition does not equal immediate destruction; mostly the records would be marked Temporary — with ‘disposal’ dates that vary greatly based on the records, what they document, etc. Very few govt records (1-3%, according to NARA) are designated as Permanent/Archival.

The request is confusing to read & follow because DOI — following NARA guidance of recent years — has moved what used to be discrete series of records with discrete records schedules (as permanent or temporary) into what are being called ‘big buckets.’ The DOI request is essentially cross-walking discrete records series to their new bucket. And made the request for all of the buckets at one time.

The volume aside, there are a number of concerning aspects to this request.

I pulled together an annotated version of the NARA appraisal memo to get a handle on what was requested – and provisionally approved by NARA. I highlighted language in the Appraisal Memo (Blue=Good retention; Green = NARA comments worth noting; Orang(ish) = Concerning), and indicated the #s of Records Groups (not #s of records) covered in each NARA appraisal entry.

One aspect that has troubled me is from DOI’s Request for Records Disposition Authority


This change to a departmental schedule, from individual bureau schedules, moves disposition authority for Record Groups 022 (FWS), 049 (BLM), 057 (USGS), 075 (BIA), 079 (NPS), 115 (BOR), 471 (OSMRE),
473 (BSEE), and 589 (BOEMRE) to 048. (which is Office of the Secretary (OS) – Record Group 048)

Regardless of who the Secretary of Interior is or may be, it gives me pause to put authority for requesting disposal for these sensitive records in the office of a political appointee. So, there is a potential question for NARA (or its Hill overseers).

I am really troubled by the repeated language — by NARA — about “interest to NARA Researchers” (as opposed to??), and that records “do not document significant actions of federal officials”.

The legal definition of Records (44 U.S.C. Chapter 33)§ 3301) is:

(1) IN GENERAL.-As used in this chapter, the term “records”-
(A) includes all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them

I would welcome your thoughts on particular sets of records/buckets and how they have been appraised — where the appraisal may fail to address the research/legal/etc needs of other communities (other than “NARA researchers”), where data, on which ongoing datasets are built, might be irretrievably destroyed, etc.

CC BY-NC-SA 4.0 This work is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.


  1. In regards to “NARA researchers” that simply means people researching archival records at NARA, as opposed to operational use of the records by the originating agency. In other words, what the memo is saying is that they don’t think anyone will use the records if they were accessioned, therefore there is no point in keeping them. Whether or not that is true is something that can be debated. I think a letter that identifies specific permanent (ie as valid 600 years from now as 50 years from now) research needs for specific categories of records and explains how those research needs could not be met by those records which are being kept permanent would be more to the point than something which nitpicks NARA’s jargon.

    • While you as an archivist may understand what “NARA researchers” are, the wider public sees sentences like “while IFTA records possess long-term legal value, they are not of interest to NARA researchers” and “This is a high-volume series that contains data and records that have scientific worth and can be re-used to create other records, but they do not have continuing value to NARA researchers” and wonders why records that are obviously worthy of preservation are still deemed “temporary” by the agency and NARA. I don’t believe this is nitpicking about jargon but a serious question about NARA’s definitions and policies.

  2. —Given the apparent assessments of what its (and the agencies’) records responsibilities are and who “NARA researchers” are, we request that DOI resubmit its Request with “obsolete” series restored.”—

    Why does DOI need to request schedules for records which are no longer created?

  3. From draft letter: “It is disturbing if this is now the standard NARA assessment of the scope of its and the agencies’ responsibilities for the preservation of records, as it is not compliant with law.”

    Apparently, this was claim was intended to be supported by quoting 44 U.S.C. Chapter 33 § 3301. What this letter fails to account for, however, is the defining something as a record is not the same as stating that it must by law be retained permanently.

    From draft letter: “Moreover, we note that “temporary” files—deemed by agency appraisers to be of “little to no research value” (see below) that do “not document significant actions of Federal officials”—are subject to increasingly narrow time horizons. Many temporary files have recommended holding periods from 0 to 5 years, while others earned a more robust and typical life span of 40 to 75 years. The former in particular would be held for arguably too narrow a time frame for researchers to meaningfully engage them.”

    These time ranges are entirely within the norm for records scheduled as temporary. The lower time ranges would be for records considered to have purely short-term administrative value to the creating agency, and no value to researchers.

    Furthermore, according to the summary given here: https://records-express.blogs.archives.gov/2018/11/19/additional-background-on-doi-records-schedule/

    173 items have the same retention period previously approved for each individual bureau.
    33 items now have an increased retention period. This is because the flexible scheduling methodology has allowed the agency to group like records together, keeping some longer than the previously approved time frames.
    15 items now have a slightly shorter retention period.

    So save for those 15 items the time horizons are not increasingly narrow, but unchanged or expanded.

    From draft letter: “For the purposes of this Comment, we strongly urge NARA to reconsider the disposition timelines for those record series in which they have made this assessment. In particular: … Item 0008: Accounting, Compliance, and Administration Records: Financial Reports/ Summaries”

    Item 0008 is scheduled as permanent. What’s the objection there?

  4. Another thought: If there really was such a a strong research interest in these records, how come it was not expressed when they were previously scheduled in 2013, 2012, 2007, 2005, 2000, 1994, 1985, or 1978?* Consider that this is not the first time around the ball park for most of these records. Most have current disposition authorities that were put up for public comment before. And no, its not because it was done in “the shadows” as some libelous commentators have suggested. There is nothing shadowy about Federal Register notice.

    *ProTip: In the old disposition authority numbers (N1 and NC1 number), the numbers after the second dash indicate fiscal year the schedule was first created. So N1-022-05-01, 47 for example would be the Record Group 22 [Records of the U.S. Fish And Wildlife Service}, Fiscal Year 2005, Job 1, Item 47. Which can be found here: https://www.archives.gov/files/records-mgmt/rcs/schedules/departments/department-of-the-interior/rg-0022/n1-022-05-001_sf115.pdf

  5. “Yet it is also unclear when cross-referencing the memo with the schedule which Cobell files precisely are slated to go.”

    Good point. I’m having a hard time with that myself. I find it odd that they call out those specific records in the introduction without stating which item they are referring to. Going through the crosswalk, my guess is Item 0007, but it is not as clear as it should be.

    And on a related note, I’m not at all keen on the format of the newer schedules, as I feel they will create certain amount of confusion on the difference between sequence numbers and item numbers.

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