John Galmiche
607G NW 23rd Street
Washington, DC 20052
Subject: National Archives and Records Administration Proposed Rule [36 CFR
Part 1250]
Date: Thursday, October 11, 2007
Dear Madam or Sir:
I?d like to express my general support for the National Archives and
Records Administration?s proposed rule to implement the Freedom of Information
Act, as amended in 1992, to increase the ease at which the public can access
federal records. This proposed rule initially looked like standard implementation of
FOIA to a federal agency, but I am convinced that it is so much more than that. I
firmly believe that the official implantation of this rule with result in the public?s
interest to learn more about what NARA has to offer.
As a college student in Washington, DC, I have seen first hand that the
national archives act as one of the best reading rooms in the city to complete
research. My senior history thesis on Revolutionary War pension records was
almost completed manufactured in a NARA reading room. I know that through the
implementation of FOIA, other college students and researchers from around the
country will have the same ability that I have had to learn incredible things about
our nation?s history.
Education must remain a staple of the American fabric, and what
better way to do this than to allow Americans easier access to the documents
that comprise out past. I was most impressed by the concerted effort to make
these documents digitally accessible. As our nation grows and the
interconnectedness of the American people becomes more dominated by the
advent of the internet, it is important for government agencies to keep up with
demands. I furthermore applaud the implementation of Executive Order 13392
which improves agency disclosure of information.
I was concerned about three things as written in the rule that I would
like to express my discontent toward. The first being the ambiguity surrounding
Executive Order 13233 which allows the president at least 90 days to make a
determination on any presidential document. The rule was very vague on what
exactly comprises a ?presidential? record. If government agencies and bureaucrats
work at the will of the president, does E.O. 13233 mean that all of these
documents are presidential? The written rule gives no explanation to my quarry.
I am also disconcerted with the supplemental information I was required to do to
make this comment viable. The new amendments to ? 1250 are completed laid
out in the proposal; however, the original text, that is what was taken out, is
impossible to gather based of the information provided in the Federal Register.
This makes it very difficult for the public to comment on anything that includes
amendments to an old rule. I had to do supplemental research on the Code of
Federal Regulations, and find out not only what the new language will say, but
also to find the language that was taken out. For example, ?Revise ? 1250.8 to
read as follows?NARA provides access to the following records?? First of all, the
public has no idea what 1250.8 was revised from, only what it was revised to, and
it is disconcerting that a bureaucrat would be able to slip in a statue that is
overlooked in the public comment period. Although my research did not amount
to any issue with this specific rule, it worries me that public comment will not be
sufficient without knowing what has been taken out of the provisions.
My final concern surrounds the period by witch NARA will respond to a FOIA
request. This leaves ambiguity surrounding the amount of days that they have to
respond to a proposed request for information. The proposed amendment to ?
1250.82 reads, ?we propose to provide a 10 day response time for the submitter,
instead of the current 5 day period.? However, under ? 1250.25, ?NARA will
acknowledge all FOIA request within 20 working days.? I am hoping that the
proposed language will clear up these ambiguities, and the rule will be accepted
without reservation.
Thank you for taking the time to read my comment on the proposed rule.
Sincerely,
John Galmiche
Comment on FR Doc # E7-17913
This is comment on Proposed Rule
Public Availability and Use of Federal Records
View Comment
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