As noted previously here and elsewhere, in response to the Obama administration’s Open Government Directive, the National Archives issued an open call for suggestions from the public about how they can increase their transparency and become more “open.” In considering how to discuss this issue here on the blog, I found it difficult to structure my response around the broad categories provided in the original call. Instead I think it’s easier to think about how to approach specific functions. And, good archivist that I try to be, my mind turns first to appraisal. If you’re not familiar with how scheduling and appraisal work at the Federal level, you may want to read “Records Schedule Review Process,” an overview created by NARA for Federal records managers. I think there are two specific areas of this process that can be significantly improved to create greater transparency and to “to improve public participation in and feedback on” this National Archives core mission activity.
First, the process for publishing proposed records schedules and receiving public feedback is need of an overhaul. Federal law requires NARA to “publish notice in the Federal Register of schedules proposing (a) the disposal of unscheduled series or (b) a reduction in the retention period of a series already approved for disposal. These notices provide the public with the opportunity to request copies of pending schedules from NARA and provide comments.” Note that the records schedule itself is not published in the Federal Register, only a notice of the schedule. Interested citizens must contact NARA and request a copy of the schedule. While this is certainly not an insurmountable barrier, given the ease with which information can now be made available to the public, wouldn’t it seem more logical to post proposed schedules on NARA’s web site and point to them from the Federal Register notice? This would also allow NARA to create an RSS feed so that interested citizens could notified when new schedules were posted. This appears to me to be a relatively simple way of increasing transparency, not only for NARA but for all government agencies. It’s possible NARA could also engage in a public dialogue with citizens about the comments received on proposed schedules. That idea may be more problematic, but it’s worth considering in the context of increasing opportunities to “improve collaboration.”
Just as I think citizens should have access to all proposed schedules, I believe it is unconscionable that the public does not have online access to the approved records schedules of government agencies. My former colleagues at NARA may think I’m putting it a bit strongly, but that’s my opinion. One of NARA’s most important functions is to determine, in consultation with agencies and the public, which records created by the government are suitable for permanent preservation. But the outcome of that process–the records schedules–are not made available to the citizens, except on request. This is an issue that relates not only to NARA’s own transparency, but also to transparency throughout government. True, some agencies do post their schedules on their own web sites, but by no means all do so. When I left NARA ideas for how to make all the approved schedules available online was still in the discussion stage and I do not know what progress or plans have since been made. However, I think the development of an Open Government Plan for NARA would not be complete without consideration of providing open access to the products of one of its most important functions.
Those are just my initial thoughts, and I’d be happy to hear what you think of them and what you think can be done to improve how NARA supports access to and feedback on scheduling and appraisal. My intent is to publish occasional posts like this one, that focus around different functional areas, between now and March 19 (the date on which comments are due to NARA). If there’s an area you’re particularly keen to discuss, let me know in the comments and I’ll make sure it’s highlighted. (Except that I think that there are many people more qualified than I to discuss how the FOIA process can be improved. That’s one I don’t plan to discuss.) But what do you think? What can NARA improve scheduling and appraisal?