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In an unusual move, the Trump Administration is separating OMB publications into two groups on the whitehouse.gov website: those from “Prior administrations” and those that are “Recent.” Thus, the White House is pointing to the obamawhitehouse.archives.gov copies of all OMB Bulletins, Circulars, and Memoranda issued prior to January 20 instead of maintaining these as part of the current whitehouse.gov website.
One Circular of particular interest to government information specialists is Circular A-130, “Managing Federal Information as a Strategic Resource.” The new whitehouse.gov website points to a copy of the A-130 Circular in the obamawhitehouse.archives.gov archive and labels it a regulation of a “Prior administration.”
According to OMB Circular No. A-1 (which was written in 1948 and revised in 1952 and is now only available from the Obama White House archive):
Circulars and Bulletins which are employed to communicate various instructions and information to the executive departments and establishments. The Circular series is used when the nature of the subject matter is of continuing effect. The Bulletin series is used when the subject matter requires single or one-time action by the departments or establishments or is of a transitory nature…. The provisions of any Circular or Bulletin, except as otherwise specifically provided in any given Circular or Bulletin, shall be observed by every such department or establishment insofar as the subject matter pertains to the affairs of such department or establishment.
It is not clear if this separation of policy documents into current and archived copies is intended to convey a change in the effective status and implementation OMB policies under the Trump administration.
There is a lot of activity going on to ensure that government information on government servers does not get altered, deleted, or lost during the transition between administrations. As we have pointed out before, this is not a new issue even if the immediacy of the problem is more apparent than ever before.
Much of the effort going into these activities has to deal with the inherent problems of how federal government agencies create and disseminate information. There is, for example, no comprehensive inventory or national bibliography of government information. Agencies do not even provide inventories of their own information. This makes it hard to identify and select information for preservation. Also, some information is in databases or linked to Web applications that are not directly acquirable by the public. Finally, the "digital objects" that we can identify and acquire are often not easily preservable.
The inherent problem is that agencies are not addressing digital preservation up front. Librarians and Web archivists are left trying to solve the digital preservation problem too late in the life-cycle of information. We are trying to preserve information long after its creation and "distribution" — in the absence of early preservation planning by the agencies that created the information. This is understandable under current government information policies because most government agencies do not have a mission that includes either the long-term preservation of their information or free public access to it. The Federal Records Act [Public Law 81-754, 64 Stat. 578, TITLE V-Federal Records (64 Stat. 583)] and related laws and regulations only cover a portion of the huge amount of information gathered and created by the government. In addition, the preservation plans that do exist are subject to interpretation by political appointees who may not always have preservation as their highest priority.
What we need is a better approach to government information management that includes preservation planning at the beginning of the information life-cycle and that guarantees its long-term preservation and free public access to it even if the agency has no more need for it, or if Congress has no more funding for it, or if politicians no longer want it.
How can that be done?
At FGI, we believe that a long term solution will require a change of government policy. That is why we have proposed a modification to OMB Circular A-130: Managing Information as a Strategic Resource that would require every government agency to have an Information Management Plan.
This seems to us to be a reasonable suggestion with a good precedent. The government agencies that provide research grants already require researchers to have a Data Management Plan for the long-term preservation of data collected with government research grant funding. A modification of A-130 would simply put the same requirement onto information produced at government expense by government agencies that the National Science Foundation (NSF) and other government funding agencies put onto the data produced by researchers with government funding.
Here is an draft of such a requirement:
Every government agency must have an “Information Management Plan" for the information it creates, collects, processes, or disseminates. The Information Management Plan must specify how the agency’s public information will be preserved for the long-term including its final deposit in a reputable, trusted, government (e.g., NARA, GPO, etc.) and/or non-government digital repository to guarantee free public access to it.
We believe that such a requirement would provide many benefits for agencies, libraries, archives, and the General Public. It would make it possible to preserve information continuously without the need for hasty last-minute rescue efforts. It would make it easier to identify and select information and preserve it outside of government control. It would result in digital objects that are easier to preserve accurately and securely. It would accomplish many of these goals through the practical response of vendors that provide software to government agencies. Those vendors would have an enormous market for flexible software solutions for the creation of digital government information that fits the different needs of different agencies for database management, document creation, content management systems, email, and so forth, while, at the same time, making it easy for agencies to output preservable digital objects and an accurate inventory of them ready for deposit in Trusted Digital Repositories (Audit And Certification Of Trustworthy Digital Repositories [ISO Standard 16363]) for long-term preservation and access.
Perhaps most important for FDLP Libraries, we believe that this OMB requirement would provide a clear and practical opportunity for libraries to guarantee long-term free access to curated collections of government information to their Designated Communities. And this, we believe, will drive new funding and staffing to libraries and digital repositories.
Jame A. Jacobs and James R. Jacobs.
As FGI readers will know, OMB has asked the public for comments and suggestions to revise its Circular A-130 “Managing Information as a Strategic Resource.” Interestingly, they have chosen to manage the commenting process on http://github.com, the collaborative software versioning and management site.
We at FGI have submitted a comment (or “issue” in GitHub parlance) at: https://github.com/ombegov/a130/issues/65. We could really use readers’ help in raising awareness of library issues at OMB and in their A-130 policy to executive agencies. Please go to GitHub and leave a comment or additional suggestion on that issue. The more comments an issue gets, the more likely that OMB will take the suggestion seriously. You can also add your own suggestions/issues [see instructions at https://a130.cio.gov].
We the FGI editors thank you for your assistance!
OMB’s Circular A-130 “Managing Information as a Strategic Resource” — along with the 1980 Paperwork Reduction Act (PRA) 94 Stat. 2812, which “establishes a broad mandate for agencies to perform their information resources management activities in an efficient, effective, and economical manner” – do not directly address and therefore have had unintended negative consequences for long-term access to and preservation of Federal government information.
These policies, along with agency practices of using the web for distribution without attending to consistent standards or to preservation, have resulted in the creation of many incompatible, inconsistent, often badly indexed and difficult to use agency web sites and a propagation of “deep Web” .gov databases. This not only makes it more difficult for individuals to find and use the government information they need, it also makes it difficult for institutions to identify, acquire, describe, and preserve agency “publication information” (defined in draft A-130 line 1066) for the long-term. Such institutions include the Government Publishing Office (GPO), libraries in the Federal Depository Library Program (FDLP), the Internet Archive, and institutions (like Sunlight Foundation, the Government Accountability Project and Open The Government) that promote open-government and government transparency.
Draft A-130 mentions “threats” on page 1, but does not mention the threat of loss of information because of insufficient preservation actions. We recommend therefore that A-130 be updated to require that all government agencies facilitate preservation of and long-term free public access to their publications. This would put the same requirement onto information produced at government expense by government agencies that the National Science Foundation (NSF) and other government funding agencies put onto the data produced by government funded research.
Every government agency should be required to have an “Information Management Plan” for the public information it acquires, assembles, creates, and disseminates. The Information Management Plan should specify how the agency’s public information will be preserved for long-term, free public access and use including its deposit in a reputable, trusted, government or non-government digital repository (including, but not limited to GPO’s FDsys). All executive agencies should deposit their publications in FDsys.gov and their data in data.gov.
As one aspect of implementation of the Information Management Plan, we recommend that every government agency be required to make its own website compatible with a few basic, consistent requirements to make it easier for the public to discover, acquire and use its information. Each agency’s site – including subdomains – should be required to:
1) Follow Web standards and design their sites with site maps. All agency sites should be Archive ready (http://archiveready.com);
2) Use a standardized directory structure that identifies major types of information (e.g., ../publications ../data ../video ../blog ../podcast ../pressreleases ../rss etc);
3) Have permanent urls in the form of DOIs or some other standard for all agency publications and other information products.
Updating A-130 for the 21st century to take full advantage of the Internet will bring executive agencies in line with the White House’s Open Government Initiative, will facilitate public access, will require the preservation of agency publications, and will facilitate economic efficiency by encouraging centralized digital preservation while allowing for the use and expansion of non-government digital repositories.
James A. Jacobs and James R. Jacobs
Free Government Information
[UPDATE 11/20/15: OMB has extended the commenting period for 15 days until December 5, 2015. JRJ]
Office of Management and Budget’s Circular A-130 Managing Information as a Strategic Resource — along with the 1980 Paperwork Reduction Act (PRA) 94 Stat. 2812, which “establishes a broad mandate for agencies to perform their information resources management activities in an efficient, effective, and economical manner” — has had a *huge* negative impact on the work of libraries and the Federal Depository Library Program (FDLP), and has had many unintended consequences for access to and preservation of Federal government information. It has made GPO’s work in maintaining the national bibliography much harder because A-130 and PRA have given Executive agencies broad leeway in publishing their information without regard for Title 44, GPO, and description and distribution of FDLP materials to libraries.
But now, OMB has requested comment on A-130 — via GitHub no less! — which hasn’t been updated since 2000. So here’s a chance for depository librarians and others to let OMB know how they can edit A-130 in order to assure free public access to — and most importantly preservation of! — federal government information and help libraries and librarians across the country deliver access and services to their communities.
We outlined some of FDLP’s needs in our 2010 Letter to Deputy CTO Noveck: “Open Government Publications” and in other places. Basically, we need executive agencies to work with GPO in creating and maintaining the national bibliography. We need executive agencies to create and follow Web standards and design their sites to make it easier for the GPO and FDLP to do their jobs — and by extension make it easier for the public to access federal information. For example, each agency should have ../publications and ../data directories (and others like ../video etc) on their sites, all of their publications should have permanent urls in the form of DOIs or some other standard, agencies should deposit their publications in FDsys.gov and their data in data.gov.
Please consider submitting comments so that the FDLP can have a federal information policy that helps libraries and GPO do their jobs.
The White House Office of Management and Budget (OMB) is proposing for the first time in fifteen years revisions to the Federal Government’s governing document establishing policies for the management of Federal information resources: Circular No. A-130, Managing Information as a Strategic Resource. More specifically, Circular A-130 provides general policy for the planning, budgeting, governance, acquisition, and management of Federal information resources. It also includes appendices outlining agency responsibilities for managing information, supporting use of electronic transactions, and protecting Federal information resources.
The proposed revisions to the Circular are the result of new statutory requirements and enhanced technological capabilities since the last update to the Circular in 2000. Modernizing this policy will enable OMB to provide timely and relevant guidance to agencies and will ensure that the Federal IT ecosystem operates more securely and more efficiently while saving tax dollars and serving the needs of the American people.
The proposed Circular reflects a rapidly evolving digital economy, where more than ever, individuals, groups, and organizations rely on information technology to carry out a wide range of missions and business functions. Information technology changes rapidly and the Federal workforce managing IT must have the flexibility to address known and emerging threats while implementing continuous improvements. This update acknowledges the pace of change and the need to increase capabilities provided by 21st century technology while recognizing the need for strong governance and safeguarding of taxpayer funded assets and information.
The proposed guidance is now open for public comment on this page. The public feedback period will be 30 days, closing on November 20, 2015. Following the public feedback period, OMB will analyze all submitted feedback and revise the policy as necessary.