The Department of Defense says a plan to go to all-digital federal records accession will cost too much and interfere with existing digitization plans.
This article was updated Sept. 12 with information from the National Archives.
The Department of Defense is pushing back on the National Archives' plan to go 100 percent digital when it comes to records management.
Under the new strategic plan, released for comment in late August, the National Archives and Records Administration said it would stop accepting non-digital records transfers by the end of 2022.
"We have heard the administration's call for a more aggressive digital government agenda. Here at NARA, we have taken it to heart to be out in front and drive the change that needs to happen to bring about a more efficient and effective digital government," said David S. Ferriero, archivist of the United States.
The digital agenda contained in NARA's plan may be too aggressive for the Pentagon.
In comments filed Sept. 1, the DOD said it "critically non-concurs" with the NARA plan to phase out analog records transfers, especially where "special media records" such as photographs, maps, videos and audio recordings are concerned.
The DOD comments, filed by Defense Imagery Management Operations Center Archivist Julia Hickey, warn that the policy could cost the department more than $37 million in unplanned digitization and storage costs between 2023 and 2027. The policy would also undermine the workflow and planning of DIMOC, which collects special media from the armed services and the Pentagon and accessions them to NARA. The center is the midst of a 10-year plan to collect physical special media records from across DOD.
"If NARA stops accepting these master records from DIMOC, our clients will be inclined to keep their media rather than transfer it," the comments said. "Ultimately, this will result in the alienation of federal records due to the declining ability to playback, preserve, and digitize legacy analog media."
The DOD has its own records management standard, and that standard informs the way record management technology solutions for government are designed. It's not clear what effect a "critical non-concurrence" from the single largest government agency will have.
"The Archivist always takes comments from agencies seriously," Jason R. Baron, a lawyer at Drinker Biddle and former director of litigation at NARA, said. "And certainly a comment from DOD that they will have special difficulties in meeting the 2022 date will be given weight."
A NARA spokesperson told FCW that the DOD's comments were taken into account in a revised draft, which was submitted to the Office of Management and Budget on Sept. 11. The new draft is expected to be released publicly next week.
"Our next draft provides more detail about how we would implement the deadline that should address some of DOD's concerns," the spokesperson said. The strategic goal of going all-digital by Dec. 31, 2022 has not changed in the new draft.