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ASEH comment to NARA regarding DOI request for records disposition authority

Response to US Department of the Interior Request for Records Disposition Authority

The National Archives and Records Administration (NARA) extended until November 26, 2018 the deadline for public comment on a Department of the Interior (DOI) Request for Records Disposition Authority. If approved, the request would set a series of schedules for the destruction or preservation of a variety of DOI records. The request amounts to a “big bucket” schedule, covering and partially consolidating records from a variety of divisions within a single agency. The records that might be destroyed range from Bureau of Land Management lease applications, to construction and operation records for various DOI buildings and infrastructural projects, to case files regarding the consideration and ultimate non-designation of critical habitats under the Endangered Species Act. ASEH is submitting the attached comment, in coordination with other scholarly organizations, urging greater transparency and restraint in the disposition of federal records. 

Background: On September 11th, NARA announced DOI’s proposal to destroy what it considered non-essential records and to preserve others. NARA granted one month for public comment. NARA then received public requests for details of the various schedules. Because NARA could not assemble a “big bucket” schedule before October 11th, it extended the public comment period two weeks, until the 29th. According to the National Coalition for History—of which ASEH is a member organization—one of the schedule requestors sought help from several organizations in pushing the deadline for comment into November and suggested that NARA was obstructing public participation. In fact, the National Coalition for History has explained, NARA was following both standard practice and the letter of the law, but it did soon extend the deadline until November 26th.  

One of NARA’s core functions is the sorting of federal documents into those to be preserved and those to be destroyed. Although this incident is an example of routine, rather than of an exception to this process, it illustrates the potential lack of transparency in the disposition of federal documents as well as the need for longer public comment periods. Along with other scholarly groups, ASEH has registered its concerns with the way in which federal documents with research value are handled.  

David Spatz, ASEH Executive Director, Graeme Wynn, ASEH President, and the Ad Hoc Committee on Political Engagement

 

ASEH Statement (submitted to NARA November 26, 2018):

            The American Society for Environmental History (ASEH) wishes to register its concern about the recent Department of the Interior (DOI) Request for Records Disposition Authority. We recognize that NARA handled the DOI’s request appropriately, but the scale of the request and the brevity of the public comment period have underscored fundamental obstacles to thoughtful and timely public participation in this process. As a scholarly organization, ASEH shares NARA’s dedication to the preservation of historically important materials, and believes that opportunities remain for improving the system by which federal documents are handled. 

            ASEH is particularly concerned with the question of which documents might or might not possess “high potential research value.” Researchers’ views on this matter often differ from the initial appraisals of an agency like DOI, and so researchers must be afforded every opportunity to weigh in on agency decisions about document disposition. Given the scope of the DOI’s “big bucket” request, the initial and even subsequent deadlines for public comment were insufficient. And misunderstandings in this case about whether NARA was in fact following proper procedure point to the need for better information—even among scholars—about what the procedure involves and where the public fits within it. Researchers could be better informed about specific requests as well as about the overall process for disposing of and preserving documents. 

            Achieving these aims will require that researchers and public agencies work together whenever possible. Many ASEH members have especially strong interest in DOI records, and so particular concern with whether those records are lost to posterity. Our strong preference, as a group of scholars concerned with people and nonhuman nature, is for maximum feasible protection of documents produced by entities such as DOI. ASEH urges NARA to consider how disposition schedules might be better made public, and how researchers such as ourselves could be better integrated into the decision-making process. 

 

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