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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.
[August 9, 2018 update] Thank you Meg Phillips, NARA’s External Affairs Liaison, for contacting me and offering additional information and context. Meg notes that “No agency may dispose of records without written authorization from the Archivist of the United States in the form of approval of the records retention schedule. That is what is going on with ICE – ICE submitted a schedule, NARA requested public comment, which it has gotten, and NARA is now working with ICE to revise the schedule.”
Because of the public interest in the ICE schedule, Archivist David Ferriero recently blogged about where NARA’s process is at, and also wrote a response to the AHA letter dated August 1, 2018 (available as a PDF).
Good on the American Historical Association for writing a letter to Archivist of the US David Ferriero to complain about the imminent destruction of records by the US Border Patrol and Immigration and Customs Enforcement (ICE). Most people do not realize that executive branch agencies get to define what constitutes a “record” and its own records schedule of what ultimately gets sent to the National Archives for preservation. NARA only offers guidance to executive agencies, they do not tell executive agencies what to preserve.
U.S. historians are rallying to stop federal immigration agencies from destroying records of their treatment towards immigrants.
In a letter addressed to the National Archives and Records Administration (NARA), which instructs federal agencies on how to maintain their records, the American Historical Association has demanded that the regulatory body shut down any “threats to the preservation of records relating to the treatment of immigrants by the U.S. Border Patrol and Immigration and Customs Enforcement (ICE).”
The letter, signed by AHA Executive Director James Grossman, comes after it was revealed that ICE had sought permission from NARA to begin destroying years’ worth of data, including information on reports of sexual abuse, solitary confinement and in-custody deaths.