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Last year, the Preservation of Electronic Government Information (PEGI) Project — a collaborative effort of which I’m a part — commented on phase I of the draft Federal Data Strategy. This time around, there was a request for comments on phase III, the draft action plan for the Federal Data Strategy and again PEGI submitted comments (grab the PDF here). They were very specific about what comments they were looking for this time around:
In March 2018, President Trump launched the President’s Management Agenda (PMA). It lays out a long-term vision for modernizing the Federal Government in key areas that will improve the ability of agencies to deliver mission outcomes, provide excellent service, and effectively steward taxpayer dollars on behalf of the American people. The PMA established a Cross-Agency Priority (CAP) goal of Leveraging Data as a Strategic Asset with an intended purpose of guiding development of a comprehensive long-term Federal Data Strategy (hereinafter “Strategy”) to grow the economy, increase the effectiveness of the Federal Government, facilitate oversight, and promote transparency (https://www.performance.gov/CAP/CAP_goal_2.html). This notice seeks comment on a draft action plan for Federal agencies to adopt in order to achieve the objectives of this CAP goal. This is the third Federal Register Notice seeking public comment related to the Federal Data Strategy. The previous two notices sought comments on the Strategy’s draft principles and draft practices, respectively.
Please provide comment on the scope and content of the 2019-2020 Federal Data Strategy Action Plan.
- Identify any additional fundamental actions to implement the Federal Data Strategy that are not included in this draft Year-1 Action Plan and explain why.
- Identify any additional actions that would align with or complement ongoing Federal data initiatives or the implementation of new legislation, such as the Foundations for Evidence-based Policy Making Act and explain why.
- Identify any actions in this draft Year-1 Action Plan that should be omitted and explain why.
- For each action, provide any edits and additional detail to ensure that they accurately and effectively describe needed activities, responsible entities, metrics for assessing progress, and timelines for completion.
- For each action, provide information about the implementation resources necessary to ensure success of these Action Steps.
PEGI focused (of course!) on the importance of data preservation and robust metadata, proposing “approaches that will maximize resource use by assuring that the implementation of the Federal Data Strategy will include preservation as a key component.” Read our comments in their entirety and also check out all of the submitted comments on regulations.gov.
As many of our readers know, Depository Library Council (DLC) recommended the creation of a working group to explore digital deposit and there was a session on digital deposit at the 2019 Spring Virtual Meeting of the DLC:
- Digital Deposit A Value Proposition, [transcript, slides, SOD 321 “Digital Dissemination of Access Content Packages for FDLP Digital Depository”, A/V of presentation (scroll down to “Digital Deposit: A Value Proposition”]. Depository Library Council, 2019 Spring Virtual Meeting (April 16, 2019). Presentations by James R. Jacobs (Stanford), Heather Christenson (HathiTrust), and Jessica Tieman (GPO).
Digital deposit should be part of FDLP for the same reasons paper deposit has been for two hundred years: it guarantees preservation of the information and provides services to users of that information. Discusions of digital deposit, therefore, should focus on preservation and users and the technologies that can enable the best digital services.
We’ve come a long way on preservation. GPO has (more…)
Twitter and newspapers are buzzing with complaints about widespread problems with access to government information and data (see for example, Wall Street Journal (paywall 😐 ), ZDNet News, Pew Center, Washington Post, Scientific American, TheVerge, and FedScoop to name but a few).
Maybe when/if the government opens again, we should scrape the NIST and CSRC websites, put all those publications somewhere public. It’s worrying that *every single US cryptography standard* is now unavailable to practitioners.
— Matthew Green (@matthew_d_green) January 12, 2019
Matthew Green, a professor at Johns Hopkins, said “It’s worrying that every single US cryptography standard is now unavailable to practitioners.” He was responding to the fact that he could not get the documents he needed from the National Institute of Standards and Technology (NIST) or its branch, the Computer Security Resource Center (CSRC). The government shutdown is the direct cause of these problems.
Others who noticed the same problem started chiming in to the discussion Green started, noting that they couldn’t find the standards they needed in Google’s cache or the Wayback machine, either. Someone else suggested that “Such documents should be distributed to multiple free and public repositories” and said that “These documents are “Too important to have subject to a single point of failure.” Someone else said that he downloads personal copies of the documents he needs every month, but had missed one that he uses “somewhat often.” One lone voice wondered about “Federal Depository Libraries, of which I believe there is at least one in every state.” (James responded to that one, letting people know about the FDLP and End of Term crawl!)
There are at least two reasons why users cannot get the documents they need from government servers during the shutdown. In some cases, agencies have apparently shut off access to their documents. (This is the case for both NIST and CSRC.) In other cases, the security certificates of websites have expired — with no agency employees to renew them! — leaving whole websites either insecure or unavailable or both.
Regardless of who you (or your user communities) blame for the shutdown itself, this loss of access was entirely foreseeable and avoidable. It was foreseeable because it has happened before. It was avoidable because libraries can select, acquire, organize, and preserve these documents and provide access to them and services for them whether the government is open or shut-down.
Some libraries probably do have some of these documents. But too many libraries have chosen to adopt a new model of “services without collections.” GPO proudly promotes this model as “All or Mostly Online Federal Depository Libraries.” GPO itself is affected by this model. Almost 20% of the PURLs in CGP point to content on non-GPO government servers. So, even though GPO’s govinfo database and catalog of government publications (CGP) may still be up and running, during the shut-down GPO cannot ensure that all its “Permanent URLs” (PURLs) will work.
This no-collections-model means that libraries are too often choosing simply to point to collections over which they have no control — and we’ve known what happens “When we depend on pointing instead of collecting” for quite some time. When those collections go offline and users lose access, users begin to wonder why someone hasn’t foreseen this problem and put “all those publications somewhere public.”
The gap between what libraries could do to prevent the kind of loss of access the shutdown is causing and what they are doing is particularly notorious in the area of government information. Most federal government information is in the public domain and is available without technical or copyright restrictions or fees. There is nothing preventing libraries from building collections to support users except the will to do so.
Many library administrators are eager to proclaim that pointing to collections they do not control is the new role of libraries in the digital age. Those who promote this new model of services without collections then struggle to demonstrate the value of libraries to their user communities. This is difficult when those communities go directly to collections of information, bypassing libraries and, perhaps, wondering why libraries still exist at all.
This represents a failure by libraries to fulfill their role in society and in the digital information ecosystem.
When the shutdown ends, access will, presumably, be restored. In the wake of the many other problems caused by the shutdown (many of them immediate and even dangerous), this temporary loss of access to some government information may not seem pressing. But librarians should see this as another wake-up call. Hopefully, Depository Library Council’s recent recommendation regarding digital deposit will answer that call. Libraries should not focus on bemoaning the short-term problem. We should, instead, focus on making the next crisis impossible. We can do this by focusing on the long-term problems of digital collection development, preservation and access. The current crisis may be temporary, but when we rely only on the government to provide access to these important resources, access will remain vulnerable to the next crisis or misstep or conscious decision to cut off access. We need to recognize that government agencies do not always have the same priorities as our users.
Today, libraries cannot ensure long-term access to government information because they do not control it. But, if libraries select, acquire, organize, and preserve the government information that is vital to their user communities, then they can ensure long-term access to it. You will not have to persuade your users of the value of your library when you do what they value.
James A. Jacobs, University of California San Diego
James R. Jacobs, Stanford University
As 2018 ends, it is time to start setting the agenda for the FDLP for 2019. This year has a lot of potential despite (or because of) the failure of Title 44 reform, the shutdown of the government, and the general political gridlock of Congress.
2018: The Year of "Modernizing"
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 [email protected]
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.
- PDF of full DOI request
- PDF of Tabular Summary (expanded so Records Descriptions are readable in full)
- PDF Appraisal memo (from NARA)
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.