400 A Street S.E.
Washington D.C. 20003
(202) 544-2422 Ext # 116


April 29, 2009

Ms. Adrienne C. Thomas
Acting Archivist of the United States
National Archives and Records Administration
Room 4200
8601 Adelphi Road
College Park, MD 20740-6001

Dear Ms. Thomas:

The National Coalition for History (NCH) is a consortium of over 60 organizations that advocates on federal legislative and regulatory issues affecting historians, archivists, political scientists, teachers, researchers, and other stakeholders.

As researchers and conservators of American history and culture we care deeply about the programs and activities of the National Archives and Records Administration (NARA). Thank you for the opportunity to submit our views in response to your request seeking suggestions on alternative models to the current the presidential library system.

We have been concerned for many years that Congress and various Administrations continually place heavier burdens on the National Archives while not providing the commensurate funding to meet these new obligations. We hope that the report to Congress on the Presidential Library system will allow both NARA, and its stakeholders, to articulate the needs of the system in manner that will clearly establish the spending priorities and resource requirements to sustain the Presidential Library system into the future without setting up a false competition for limited resources between infrastructure and program needs.

The earmark process has exacerbated this financial situation. We note with concern the amount of funds that have been specially earmarked for individual Presidential libraries in NARA’s appropriations bills in recent years. We agree with the mandate that Congress set forth in Public Law 111-404 that NARA include in its annual budget a capital improvement plan for the presidential library system. 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.

As historians and archivists our fundamental interest is in the preservation of and access to the records and artifacts of presidential administrations as materials of enduring value to scholars and the public. Hence, we are pleased that among the objectives Congress asked NARA to consider in developing alternative models for Presidential Libraries are improving the preservation of presidential records and reducing the delay in public access to all presidential records. As taxpayers we also appreciate the desire of Congress to reduce the federal financial burden for administering the Presidential Libraries. Finally, as citizens we recognize that the essential responsibility for preserving these records and artifacts for future generations is a public, not a private trust.

Although it may be useful to consider new and distinct alternative models for future Presidential libraries, it is probably more realistic to think that such libraries will evolve out of the existing models, and that the existing institutions will adapt some aspects of future Presidential libraries. Therefore, we present below several suggestions that we believe will incrementally address the objectives articulated by Congress.

1. 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). The geographic decentralization of the libraries provides significant benefits to the communities where they are located, but certainly adds duplicative capital and administrative costs and makes research across administrations more difficult and costly. We understand the financial benefits that each non-profit organization contributes to reducing the public investment in these institutions, and we applaud the recent statutory changes that increased the endowment requirements. Nevertheless, over time these non-profit organization are a diminishing source of financial support as a particular former president’s influence wanes and key supporters pass on. It is also clear that the mandates to preserve and make available public records and public artifacts are public responsibilities requiring public funding. Finally, we see some significant opportunities 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.

2. Declassification: The National Coalition for History supports many of the recommendations found in the Public Information Declassification Board’s (PIDB) Report entitled “Improving Declassification” that was submitted to President Bush in 2008. One of the issues addressed in the PIDB report was expediting the declassification of Presidential records. We strongly agree with the PIDB that the current process takes far too long. We have repeatedly argued that Executive Order 13233 issued in 2001 by President Bush setting procedures for the handling of Presidential records was exacerbating delays in the release of these materials. We feel that the new Presidential records Executive Order 13489 issued by President Obama will help reduce delays and backlogs. And hopefully Congress will soon enact pending legislation to make needed changes to the Presidential Records Act.

We support the PIDB’s recommendation calling for the creation of a National Declassification Center in Washington to expedite the declassification of materials held by federal departments and agencies. Centralizing declassification activities at a single entity within NARA would help alleviate logjams caused by multiple agency review of equities, inconsistent application of declassification criteria and foster the development of a cadre of declassification specialists.

The PIDB also 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.

We assume the Presidential records declassification center would be housed and integrated within the National Declassification Center or absent of the creation of the NDC it would be a stand-alone entity. In fact the PIDB report recommends that if a separate Presidential records center for the storage and review of classified records is not established, that the NDC should internally create a separate office dedicated to the review of records requested by the presidential libraries.

We agree with the PIDB that 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.

Adopting the PIDB recommendations will reduce the federal financial burden associated with the Presidential libraries, and should expedite public access to presidential records.

3. White House 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. Moreover, adapting proven concepts, standards and processes for managing these materials throughout their life cycles from administration to administration will minimize future costs for updating the technology used to accomplish these tasks.

4. 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. That said, we have yet to see the successful implementation of key modules of the ERA system. Moreover, without the preservation capabilities envisioned by ERA, the idea of scanning the vast collections currently held by the Presidential Libraries to allow for centralized archival management and decentralized dissemination via the web (thus eliminating the need for on-site archival storage and research facilities) seems premature.

Beyond ERA, we recommend that NARA seek to take full advantage of proven, and where possible open source, solutions to manage all appropriate aspects of the Presidential Library system. Recognizing that technology evolves, often at an accelerating pace, NARA should develop and implement a long term technological plan that avoids the proliferation of unique, proprietary systems across the presidential libraries, and provides for the routine upgrade of systems to take advantage of new technological developments and ensures consistency throughout the presidential library system. Along the lines of the plans for ERA, where possible the technology used in the presidential libraries should also be integrated with other technology systems performing similar functions for other NARA operations.

5. Balancing the Demands of Preservation and Access: As one alternative model, 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 believe that this proposed alternative accepts the current status quo where limited resources always require substantial trade-offs between preservation and access. Congress has given NARA the mission is to do both, and NARA should present a vision, plans, and budgets that will accomplish both missions in the public interest.

We agree that systematic processing of records using the most cost-effective processing techniques, and well-thought priorities will ultimately reduce the federal financial burden and improve the preservation of presidential records. Our suggestions detailed above regarding the integration of NARA requirements with White House records systems should ultimately make the processing of presidential records significantly more efficient. We recognize that access is typically more efficient and complete in processed collections, but we also know that it is possible to reasonably search unprocessed collections regardless of format. Establishing processing priorities to better synchronize access demands with processing schedules is another key aspect of this problem that is currently not only driven to some extent by the public demand for access through FOIA, but also the demands of the current and former presidential administrations.

We recommend that NARA make its approach to establishing processing priorities for presidential records more systematic and transparent. NARA should systematically set processing priorities by drawing on its past experience with previous administrations and what it knows about the series of records that are typically in greatest demand in the years immediately following a presidential transition and its understanding of national security classification guidance and other access restrictions that will likely preclude the release of certain information for many years.

NARA should also seek formal input from both the incoming and outgoing administrations so that records needed to conduct current business and the activities of the former president and the presidential library foundation are readily available. Finally, after reconciling these various inputs NARA should publish its processing schedule in the Federal Register and provide routine updates on its processing progress, to help manage the expectations of interested parties.

Thank you again for the opportunity to express our views on this important topic.


Lee White
Executive Director
National Coalition for History