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Natural Resources Defense Council (NRDC) submits comment to NARA re Dept of Interior records schedule request
The Natural Resources Defense Council (NRDC) just sent me a PDF copy of the comment that they submitted to the National Archives and Records Administration (NARA) regarding the Department of Interior records schedule request. This letter, combined with the others from DLF, transparency organizations, and Stanford Libraries offers a finely grained analysis of the overall problem and suggestions for moving forward in making the scheduling process much more transparent and in understanding and preserving important government records. Many thanks to these organizations and the many others who submitted comments.
The Natural Resources Defense Council (NRDC) is a non-profit organization dedicated to safeguarding the earth: its people, its plants and animals, and the natural systems on which all life depends. On behalf of our over 3 million members and online activists, NRDC submits the following comments regarding the Department of the Interior’s proposed updates to its records schedule, DAA-0048-2015-0003. See Notice of availability of proposed records schedules, 83 Fed. Reg. 45,979, 45,980 (Sept. 11, 2018). NRDC also joins the letter submitted by the Emmett Environmental Law and Policy Clinic at Harvard Law School. We appreciate the willingness of the National Archives and Records Administration to work with interested parties and extend the comment period to permit public inspection of Interior’s retention policy for such vital records.
The proposed schedule covers records that are central to the public’s understanding of the Department of the Interior’s (“Interior’s”) stewardship of our nation’s public lands and natural resources. Moreover, it encompasses records of activities that might have long-lasting or permanent implications for both human health and the environment. But the proposed schedule permits some records to be destroyed while they may still be substantially valuable to the public, while other retention policies are too vague to assess their impact. Moreover, the high publicity and comprehensive nature of Interior’s schedule change highlights shortcomings in NARA’s approval process for agency records schedules. Interior’s records schedule should be amended to ensure that valuable records are preserved for public inspection.
Digital Library Federation and government transparency community submit comments to NARA re DoI records schedule
Today was the last day to comment on the draft Department of Interior records scheduling request (originally posted here on FGI “Holes in History: The Dept of Interior request to destroy records.”). I’m aware that 2 groups — the Digital Library Federation’s Government Records Transparency and Accountability working group (GRTA) and a broad coalition of government transparency organizations including Government Information Watch, FGI, Defending Rights & Dissent, Demand Progress, Public Citizen, FracTracker Alliance, National Coalition for History, Association of Research Libraries, Rural Coalition, Society of Professional Journalists, Project On Government Oversight (POGO), and ICPSR — have submitted comments and listed concerns and ideas for how to make the records scheduling process more transparent. I think these letters, combined with Stanford UL’s letter to AOTUS Ferriero, raise important points and issues in the records scheduling process in general and in the Department of Interior’s request specifically and give suggestions for how to make the process more transparent and publicly accessible.
NARA does yeoman’s work and is critical to the public understanding of the workings of our government. Hopefully, these and other comments received by concerned citizens and organizations will improve access and preservation of important records.
On December 18, 2015, a group of 16 librarians wrote an open letter to GPO regarding the implementation of the new Regional discard policy (here’s more on our coverage of the regional discard policy). The letter asked a series of questions that the signatories felt would need to be thought about — if not answered — to inform the test phase of the policy, questions needed to evaluate the new policy’s effects and effectiveness.
One month later, there has been no response from GPO. There was, however, a response on January 6, 2016 posted to govdoc-l by the Depository Library Council (DLC). We include the full text of that response below.
We at FGI have been long-time supporters and agitators for the US Census and its companions, most notably the American Community Survey (ACS) — see for example “Fear, uncertainty, or doubt? Why the Census and ACS are critical to a well-functioning democracy.” So it was a complete shock to the system to learn about the Orwellian bill H.R. 1638: Census Reform Act of 2013 making its way through Congress. And we were so happy to learn that Kathy Karn Carmichael, Documents Librarian/ Instructor of Library Science at the University of South Carolina Aiken was going to be in Washington DC and planned to drop off letters of concern to Congressman Duncan’s office.
My colleague Kris Kasianovitz and I hastily wrote a letter (attached PDF and below), sent it to our University Librarian for approval, and were extremely grateful that he approved it and agreed to add his name to it. We sent a PDF copy to Kathy who added it to her own letter (attached PDF and below), and then sent paper copies to Congressman Duncan, the 14 co-sponsors of the bill, the Chairs and ranking members of the 3 committees taking up the bill, as well as to Congresswoman Anna Eshoo, [D-CA18], Congresswoman Zoe Lofgren, [D-CA19] and our 2 Senators Feinstein and Boxer.
But a bill like this demands more than a letter of concern. So we’re posting our letter here on FGI for others to copy/crib and otherwise use as a template for letters of your own and to pass around to friends, family and colleagues, especially to those in districts represented by Congressman Duncan and the other 14 co-sponsors. Kathy has also generously allowed us to post her letter as well. We’d be happy to post copies of others’ letters as well. Help us assure that HR1638 “Census Reform Act of 2013” does not move beyond committee and does not rear its ugly head again.
June 13, 2013
The Honorable Jeff Duncan
116 Cannon House Office Building
United States House of Representatives
Washington, DC 20510
Dear Representative Duncan:
I am writing regarding H.R. 1638, the Census Reform Act. As a librarian in the Federal Depository program, I am opposed to eliminating the various censuses targeted in this legislation. This data provides valuable, free information, not only to the citizens of South Carolina and the entire country, but to local, state, and federal governments so that they may assess the needs of their constituents. Furthermore, it provides information which is not available elsewhere to business leaders, entrepreneurs and researchers.
In addition to my responsibilities as the FDLP coordinator, I am also a reference and instruction librarian at University of South Carolina Aiken. As a frequent user of this data I am able to assist students, faculty, and citizens in this community with their government information research needs. Additionally, I work with clients of the South Carolina Small Business Development Center to help them access government information to prepare business plans or market analyses. Only last week, I was assisting one of their clients with her market analysis. The American Community Survey provided access to data which helped demonstrate the need for a type of healthcare service which is unavailable in our small community and would prevent patients from seeking treatment across the state line in Georgia. You, as a former small business owner, are aware of the challenges in beginning a new business. The ability to access demographic and economic data at no cost which might help these entrepreneurs better understand their target market is vital to ensure their future success.
According to your website, this legislation is in response to complaints by South Carolinians who feel these censuses, in particular the American Community Survey, are too intrusive. Living in the age of social media and electronic information and given the recent revelations regarding the government’s access to private information of its citizens without our knowledge, asking questions about the size of your property or the distance of your commute seems trivial. Eliminating these data collection programs impact all Americans. If implemented it would severely limit the ability of all librarians to assist the constituents of the other 434 members of Congress with accessing timely demographic information. I hope you will reconsider moving forward with this legislation and look for alternative methods to resolve the concerns of your constituents.
Kathy Karn-Carmichael, MLS
University of South Carolina Aiken
Aiken, SC 29801
June 17, 2013
The Honorable Jeff Duncan
116 Cannon House Office Building
United States House of Representatives
Washington, DC 20510
Dear Congressman Duncan,
We are writing to express our grave concern regarding 113 HR 1638, the “Census Reform Act of 2013,” the bill you introduced on April 18, 2013. This bill, rather than “reforming” the Census, will eliminate the collection of the nation’s most critical statistical instruments and cause the nation irreparable harm in negatively affecting public policy planning, scientific and academic research, and the economy. As we understand it, HR 1638 calls for:
1) The repeal and cancellation of certain census activities including the census of agriculture, census of governments, economic census, etc.;
2) curtailing the Census Bureau from conducting any census, survey, sampling or questionnaire including the American Community Survey (ACS) and rescinding any unobligated moneys to carry out the ACS;
3) prohibiting surveys or questionnaires and limiting statistics collected in a decennial census;
4) Repeal of the Census of Agriculture act of 1997.
The US Census is enshrined in the US Constitution (Article I, Section 2) and was a significant act by our founders of empowering the people over unruly governments. The legality of the Census has been repeatedly affirmed by the courts. The gathering of information is done in accordance with the US Constitution under the authority of Congress and is regulated by other laws and regulations. The various Census instruments – including the American Community Survey (ACS) – are implemented in a careful, public way under the Constitution, the U.S. Code, and the Code of Federal Regulations – all with the approval of the courts.
Today the data gathered by the Census Bureau is used by US citizens, businesses, and researchers and students across the hard- and social sciences and humanities – many of whom access current and historic data in Federal Depository libraries across the country – to measure our economy, know how to adjust spending for and develop social, financial and economic programs, and ensure that we are producing crops and livestock to support consumption and trade.
Here are just some of the uses for Census data :
• Attracting new businesses to state and local areas.
• Forecasting future transportation needs for all segments of the population.
• Planning for hospitals, nursing homes, clinics, and the location of other health services.
• Designing public safety strategies.
• Making business decisions.
• Economic development of rural areas.
• Planning urban land use.
• Creating maps to speed emergency services to households in need of assistance.
• Planning investments and evaluating financial risk.
• Facilitating scientific research.
• Providing evidence in litigation involving land use, voting rights, and equal opportunity.
• Drawing school district boundaries.
• Assessing the potential for spread of communicable diseases.
• Drawing federal, state, and local legislative districts and re-apportioning seats in the House of Representatives.
These data that HR 1638 seeks to destroy underpin and are critical to sound policy-making. Without it, the US Congress, State and local governments, businesses, academia, the American people and the libraries which serve them will be flying blind in terms of public policy, planning and ensuring that the US is on sound economic footing. We strongly urge you to reconsider and withdraw HR 1638.
Michael A. Keller, University Librarian*, Stanford University
James R. Jacobs, FDLP Coordinator, Government Information Librarian*, Stanford University
Kris Kasianovitz, Government Information Librarian*, Stanford University
123D Cecil H. Green Library
Stanford, CA 94305
*title and address used for identification purposes only.
cc Congresswoman Anna Eshoo, [D-CA18] Congresswoman Zoe Lofgren, [D-CA19]
Bill co-sponsors: Jason Chaffetz [R-UT3]; Andy Harris [R-MD1]; Walter Jones [R-NC3]; Steve Pearce [R-NM2]; Reid Ribble [R-WI8]; Steve Southerland [R-FL2]; Raúl Labrador [R-ID1]; Thomas Massie [R-KY4]; Bill Posey [R-FL8]; Steve Stockman [R-TX36]; Howard Coble [R-NC6]; Todd Rokita [R-IN4]; Jim Bridenstine [R-OK1]; Austin Scott [R-GA8]
Chairman Steve King and Marcia Fudge, ranking member, House Committee on Agriculture: Department Operations, Oversight, and Nutrition
Chairman Rep. Harold “Hal” Rogers [R-KY5] and Ranking Member Rep. Nita Lowey [D-NY17], House Committee on Appropriations
Chairman Rep. Darrell Issa [R-CA49] and Ranking Member Rep. Elijah Cummings [D-MD7]
Senator Diane Feinstein
Senator Barbara Boxer