NCH Comments on Presidential Library System

In March, the National Archives and Records Administration (NARA) sought public comment on cost effective ways of modifying the present system for archiving and providing public access to Presidential records. On April 29, the National Coalition for History submitted its comments to NARA. To see a copy of NCH’s letter to NARA, click here. The deadline for submitting comments to NARA has been extended until May 22.

The Presidential Historical Records Preservation Act of 2008 (PL 110-404) contains several provisions related to Presidential libraries and the system for archiving Presidential records. The Act requires the Archivist by this July to submit to Congress a report that provides alternative models for Presidential libraries that would “1) reduce the financial burden on the Federal Government, 2) improve the preservation of presidential records, and 3) reduce the delay in public access to all presidential records.”

NCH’s comments focused on six topics: funding, centralization, declassification, White House coordination with NARA, technological isssues and balancing the demands of preservation and access. Here is a summary of the major points from NCH’s comments.

1. Funding: NCH expressed concerns that Congress and various Administrations continually place heavier burdens on the National Archives while not providing the commensurate funding to meet these new obligations. Presidential libraries should not merit special earmarks for facilities maintenance while core services and programs both at the libraries and throughout NARA, such as research room hours, archival staff and the National Historical Publications and Records Commission, are cut or face elimination.

2. Centralization: The Presidential Library system is by definition decentralized geographically, operationally, and financially (through the operation of distinct non-profit organizations that support the initial development and to varying degrees the ongoing operation of the libraries). However, significant opportunities exist to meet Congress’ objectives by providing for centralized operations in key areas including declassification; improved integration of White House and NARA procedures and processes for creation, acquisition, and transfer of records and artifacts destined for a Presidential Library; and the use of technology.

3. Declassification: The current declassification process for presidential records takes far too long. NCH supports the creation of a National Declassification Center in Washington to expedite the declassification of materials held by federal departments and agencies. In its 2008 report to the President, the Public Interest Declassification Board (PIDB) recommended the creation of a single center within the Washington, D.C. metropolitan area, to house all future classified Presidential records from the end of a Presidential administration until their eventual declassification, at which time, they would physically be transferred to the appropriate presidential library and made available to the public. Assuming the availability of resources, this would be the preferable way to address the issue.

If the decentralized system is retained without any changes then NARA needs to reallocate resources to augment the archival capabilities at the Presidential libraries. As we have seen, the amount of records generated by each Administration continues to grow exponentially and the backlogs will only increase as the use of electronic records proliferates.

4. Greater White House/NARA Coordination: For years, archivists and historians have called for improved coordination between NARA and the White House with regard to effective transfer of records and artifacts from the Executive Office of the President to NARA. There is room for significant savings over the life-cycle of presidential records and artifacts, if the issues related to long term arrangement, description, preservation of, and access to these materials were consistently coordinated between the White House and NARA from the beginning of each administration. Another benefit of such integrated efforts would be the reliable identification and preservation of all presidential records of enduring value, and preventing the loss of such essential evidence before it reaches NARA’s custody.

5. Technology: In the long term, effective use of various tools such as the Electronic Records Archive (ERA) system and digital scanning technology will certainly change the way we do research and tend to eliminate the need for physical research rooms. These tools will allow for centralized preservation and storage of records and broadly decentralized access to these materials. This will not happen overnight, and will not be without significant costs, but NARA needs to plan carefully for this transition and coordinate with the Obama administration and future presidential administrations to ensure that taxpayers and patrons realize the full benefit of these technological advancements.

6. Balancing the Demands of Preservation and Access: As one alternative model in the notice seeking comment, NARA asserts that, “Presidential records can be processed more efficiently if they are processed systematically rather than under FOIA during the years in which the Presidential Records Act (PRA) restrictions apply…”

The work of systematic processing need not, and should not be done at the expense of public access to public records. We strongly oppose any alternative that would set efforts to process records systematically over and above public access to presidential records via the FOIA during the 12-year period when the Presidential Records Act restrictions apply. On the contrary, FOIA should be given greater support. Indeed, as suggested above, the nature and extent of past and current FOIA requests should be factored into processing schedules.

We recommend that NARA make its approach to establishing processing priorities for presidential records more systematic and transparent.

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