Letter: Act to preserve electronic records needs funding support
A reader doesn't want to see the Electronic Communications Preservation Act become another "unfunded mandate."
Regarding "Sprehe: Keeping it digital": Not sure that I'm in full agreement with this article and the understanding of the roles of the agencies and [the National Archives and Records Administration] in this.
There are plenty of existing regulations related to the management of Federal records generated in electronic formats included in 36CFR Part 1234, and especially in Subpart C. They clearly state the obligations for their management if a decision is made to create them electronically in the first place, and while e-mail (in 36CFR Section 1234.24(3)(ii)(d)) is given the ultimate out of being printed and managed as paper, that is a last resort.
The real problem here is a lack of enforcement of existing regulations and a failure to adequately fund agencies to meet the obligations set forth in federal guidance that already exists.
Insufficient funding is provided to procure systems, deploy products, manage content, and ultimately store and care for electronic format records by federal agencies. Training is barely provided for the proper management of records in paper forms by the existing staff, which in most agencies is severely inadequate to accomplish the work.
I applaud the efforts of the House Committee to generate the [Electronic Communications Preservation] Act, and think it's long overdue...but I also encourage them to open up their pocketbooks and adequately fund the corresponding purchases and training, along with staffing and the necessary "care and feeding" electronic format records require to remain persistently accessible.
Let's not let this become another one of the government's famous "unfunded mandates" that passes and then cannot be effectively enacted by the impacted parties. And keep in mind, 36CFR Section 1234.10(k) also pushes these requirements onto federal contractors who will need requisite funding to accomplish this on behalf of the agencies they do work for.
Larry Medina
What do you think? Paste a comment in the box below (registration required), or send your comment to letters@fcw.com (subject line: Blog comment) and we'll post it.
There are plenty of existing regulations related to the management of Federal records generated in electronic formats included in 36CFR Part 1234, and especially in Subpart C. They clearly state the obligations for their management if a decision is made to create them electronically in the first place, and while e-mail (in 36CFR Section 1234.24(3)(ii)(d)) is given the ultimate out of being printed and managed as paper, that is a last resort.
The real problem here is a lack of enforcement of existing regulations and a failure to adequately fund agencies to meet the obligations set forth in federal guidance that already exists.
Insufficient funding is provided to procure systems, deploy products, manage content, and ultimately store and care for electronic format records by federal agencies. Training is barely provided for the proper management of records in paper forms by the existing staff, which in most agencies is severely inadequate to accomplish the work.
I applaud the efforts of the House Committee to generate the [Electronic Communications Preservation] Act, and think it's long overdue...but I also encourage them to open up their pocketbooks and adequately fund the corresponding purchases and training, along with staffing and the necessary "care and feeding" electronic format records require to remain persistently accessible.
Let's not let this become another one of the government's famous "unfunded mandates" that passes and then cannot be effectively enacted by the impacted parties. And keep in mind, 36CFR Section 1234.10(k) also pushes these requirements onto federal contractors who will need requisite funding to accomplish this on behalf of the agencies they do work for.
Larry Medina
What do you think? Paste a comment in the box below (registration required), or send your comment to letters@fcw.com (subject line: Blog comment) and we'll post it.