From: Michael A. Keller <[log in to unmask]>
Date: Fri, Nov 2, 2018 at 6:26 PM
[N.B. MODERATOR'S NOTE: This is a crucial issue for libraries' attention
and action.]
2 November 2018
David Ferriero
Archivist of the United States
National Archives and Records Administration
700 Pennsylvania Avenue, NW,
Washington, DC 20408
National Archives and Records Administration (NARA)
[log in to unmask]
fax: 301-837-3698
NARA (ACRA)
8601 Adelphi Road
College Park MD 20740-6001
Re: Department of the Interior Records Destruction Request
#DAA-0048-2015-0003.
Dear Archivist Ferriero:
It has come to my attention that the US Department of Interior (DoI) has
submitted to the National Archives and Records Administration (NARA) a
draft *Request for Records Disposition Authority* (DAA-0048-2015-0003)
requesting permission to schedule records for disposal going back 50 years
as well as dates forward from every agency within the Department, including
the Bureau of Land Management (BLM), Bureau of Ocean Energy Management
(BOEM), National Park Service (NPS), US Fish & Wildlife Service (FWS), US
Geological Survey (USGS), Bureau of Safety and Environmental Enforcement
(BSEE), Bureau of Indian Affairs (BIA), and others.[1]
<#m_-5100891371508077550_m_-5701759756635030144__ftn1> These important
records touch on a range of critical research subjects including oil and
gas leases, mining, dams, forests, marine conservation, endangered species,
critical habitats, land acquisition and use, etc. In NARA’s appraisal memo,
most of these records have been misclassified as “temporary” with the
justification that they have “little to no research value.”
I object strenuously to such a large-scale disposition of important public
records without adequate public input. Further, I urge NARA to reconsider
the proposed records retention schedule relating to the disposition of this
wide swath of important DoI records.
Specifically, I recommend:
1. That NARA deny the proposed change of “disposition authority” from
individual bureaus (USGS, BLM, BOER etc) to the office of the Secretary of
Interior. While consolidation might correct the inefficiencies that DoI
asserts, it could also have two significantly deleterious side-effects.
First, it would give more control of records retentions decisions to the
office of a cabinet-level political appointee, making too easy the overlay
of political concerns on records retention across the entire agency going
forward. Second, it could make it more difficult for those Bureau staff who
have most familiarity with the records to have direct and informed
engagement in records classification and records retention decision-making.
2. That additional time be allocated so that researchers and the public
can have more time to identify those records that have long-term research
value. Examples of such records include, but are not limited to:
1. Items in the proposed DoI crosswalk document that contain
important observational data that can’t ever be replaced or recreated.
These include *Endangered Species Recovery Plan Files and Wildlife
Data*, *Fish & Wildlife Surveys, Critical Habitat Designation, and
Revocation Case Files*, *Energy & Minerals Accounting, Compliance,
and Administration Records Federal Files*, *Energy & Minerals
Application Case Files*, *Resources Analysis and Evaluation*, *Land
Use Planning Materials for Land Use Activities, Special Land Use Permit
Case Files*, and *Land Title, Operations and Realty*, and *Water
Project Contracts, Engineering, and Water Quality* – Proposed Items
0048-2015-0003-0001, 0004, 0006, 0007, 0009, 0010, 0011, 0012*,
0013, 0014,
0015, 0019*, 0022, 0023*).[2]
<#m_-5100891371508077550_m_-5701759756635030144__ftn2>
2. Records referencing the lawsuit *Cobell v. Salazar*, the largest
class-action lawsuit in history against the US government over
Indian trust
funds, which were misfiled under Energy & Minerals rather than BIA and
labeled “temporary.”
In addition, to increase the accuracy of the process of identifying records
that have long-term value to the public and researchers, I recommend that
NARA implement new ways to encourage public participation in the process
and new ways to make participation easier. I would hope that NARA would
consider using technological tools such as RSS and APIs that would allow
the public to more easily search, browse, and discover announcements,
documents, and the progress of the departmental scheduling process.
As you know, this large and complex scheduling request by the DoI has
brought the attention of the public both to this schedule and to the
records scheduling process in general. This offers an excellent opportunity
for NARA to re-evaluate its procedures and policies and align them to wider
government efforts and initiatives in government transparency, FOIA, open-
and big data, and data management. I recommend that re-evaluation and
re-alignment
NARA’s work in preserving records of the US government is critical to the
exercise of good government and the protection of the historical record.
NARA’s appraisal policy[3]
<#m_-5100891371508077550_m_-5701759756635030144__ftn3> notes that its
mission is to ensure “for the Citizen and the Public Servant, for the
President and the Congress and the Courts ready access to essential
evidence.” These DoI records comprise some of the the very core essential
evidence of the National experience. The inadvertent or deliberate disposal
of critical records will hamper environmental and scientific research as
well as the development and the creation of public policy both now and in
the future. Robust public participation is essential to avoid that problem
and the current public interest in these records offers NARA an opportunity
to solicit additional public participation in these critical decisions.
Therefore, I request that NARA delay the approval of the DoI schedule to
allow more time for public examination of and comment on this complex
proposal and to reevaluate these records in line with public interest and
comments and its own appraisal policy and with an eye toward potential
research value.
Thank you for your attention to this matter.
------------------------------
[1] <https://mail.google.com/mail/u/0/#m_-5701759756635030144__ftnref1>
Dept of the Interior: Records Destruction Request.
https://altgov2.org/doi-records-destruction/
[2] <https://mail.google.com/mail/u/0/#m_-5701759756635030144__ftnref2>
Only 3 out of 416 proposed items pertaining to data are listed as
“permanent” in the draft DoI crosswalk: 0012 Lease Case History Files
(energy & minerals), 0019 (Land use planning management plans and reports),
and 0023 (Historic water and power projects).
https://records-express.blogs.archives.gov/wp-content/uploads/2018/10/DRS-Mission-Bucket-2-2-Crosswalk-Full-Descriptions.pdf
[3] <https://mail.google.com/mail/u/0/#m_-5701759756635030144__ftnref3>
NARA, *Strategic Directions: Appraisal Policy*.
https://www.archives.gov/records-mgmt/initiatives/appraisal.html
Yours truly,
Michael A. Keller
Vice Provost and University Librarian; Director of Academic Information
Resources
Vice Provost for Teaching and Learning
Publisher Stanford University Press
*Stanford University*
*Stanford Libraries:*
101 Green Library
Stanford, CA 94305-6004
U.S.A.
voice: +1-650-723-5553
fax: +1-650-725-4902
*Division of Teaching and Learning:*
408 Panama Mall
Stanford, CA 94305-4036
USA
Voice:(650) 498-8181
fax:(650) 725-2868
email: [log in to unmask]
homepage: https://profiles.stanford.edu/michael-keller
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