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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.
Last week, we posted a story “Holes in History: The Dept of Interior request to destroy records” in which we raised issues concerning NARA’s records scheduling process in general and the DoI request in particular.
Today my University Librarian Michael Keller sent a Letter to Archivist of the US David Ferriero re the DoI records destruction request (text attached and below). We strongly recommend that all of our readers submit comments to NARA by November 26, 2018 (Be sure to say that you’re referring to DAA-0048-2015-0003). Here’s the address:
- [email protected]
- fax: 301-837-3698
- NARA (ACRA), 8601 Adelphi Road, College Park MD 20740-6001.
[Editor’s note: please scroll to the end of this post for a sample letter to submit to NARA. Thanks!]
[Update: 10/30: I added another point about disposition authority. JRJ]
Remember, we have until November 26, 2018, to make comments to the National Archives. (Be sure to say that you’re referring to DAA-0048-2015-0003.)
[email protected] fax: 301-837-3698 NARA (ACRA), 8601 Adelphi Road, College Park MD 20740-6001.
Last week, Russ Kick announced that The Department of the Interior (DOI) was requesting permission from the National Archives and Records Administration (NARA) to destroy documents about oil and gas leases, mining, dams, wells, timber sales, marine conservation, fishing, endangered species, non-endangered species, critical habitats, land acquisition, and lots more. The request includes documents from every agency within the DOI, including the Bureau of Land Management, National Park Service, US Fish & Wildlife Service, US Geological Survey, Bureau of Safety and Environmental Enforcement, Bureau of Indian Affairs, and others. Please read Kick’s whole post for context and comments.
This is a massive proposal. As Kick notes:
This covers already-existing documents going back more than 50 years. Thousands of cubic feet of paper documents. Gigabytes of digital documents. Besides existing documents, as usual the proposed schedule will also apply to all future documents created in these categories (whether on paper or born digital).
In a recent post on the blog of the Web Science and Digital Libraries Research Group, Shawn Jones reports on research that is vital to all those interested in long term access to government information.
- How well are the National Guideline Clearinghouse and the National Quality Measures Clearinghouse Archived? Shawn M. Jones, Web Science and Digital Libraries Research Group (July 15, 2018).
In the post, Jones reports on his research into how much of the content of two sites (more…)
The so-called FDLP Modernization Act of 2018 (H.R.5305) corrects many of the flaws of the 1993 law. It catches the law up to what it should have been in 1993 and conforms to current GPO practice. Specifically, it requires GPO to provide free access to digital content; it requires GPO to have a program of digital preservation; it changes the scope of GPO and FDLP with new definitions of “Information Dissemination Products” (IDPs) — a term used by OMB since 1996; and it requires GPO to abide by existing privacy laws (going back to 1974 and 2002).
These are welcome improvements, but they fall short of “modernizing” the law to the conditions of 2018 and beyond. A few small changes can go a long way to truly modernizing the law. These changes will create a collaborative, digital FDLP; guarantee long-term, no-fee access to government information insulated from federal political and economic pressures; and enhance services to users.