NDC Prioritization Plan Comments

Welcome to the NDC Blog.  I hope that over time this forum will become a place to discuss the NDC and report on its progress.  The NDC recently published a draft Prioritization Plan.  The plan focuses on moving the approximately 408 million pages of accessioned Federal records to the open stacks and clearing referrals in the Presidential Libraries Remote Archives Capture (RAC) program.  I invite you to read the plan and provide your comments and suggestions here.  A copy of the plan may be found at the following link: http://www.archives.gov/declassification/ndc/prioritization-plan.pdf

12 thoughts on “NDC Prioritization Plan Comments

  1. Maarja,
    Thanks for being the first to comment on the NDC Blog! I hope you will be able to attend the forum on June 23. Anyway, here are some answers to your questions.
    1. The chart on page 4/5 is meant to focus on the records of the highest priority, Category 2 for Federal records on the left side, and selected referrals for Presidential materials in the Remote Archives Capture (RAC) on the right. For Federal records, category 1, 3, and 4 record groups are listed in the Appendix.
    2. Good point about special media. We deliberately started out with paper records. We are working on models and IT systems for review of classified special and electronic media. As for the Haldeman and Erlichman files, what would be going into the RAC for review would be the withdrawn items that were referred to one or more agencies for review.
    3. Yes, defining what makes records “high interest” is is in the eye of the beholder. What we did for a baseline is looked at NARA’s reference requests over time. Asking for input from outside of NARA will provide us with an additional barometer on what people want. We are also considering likelihood of declassification in deciding what to process first.
    4. Yes, I think it’s a good idea to let people know that the plan could change if circumstances do. Also, with regard to Kyl-Lott, DOE has been participating in the NDC.

  2. Thank you so much, Don, that clears it up considerably. I very much appreciate the good response. I think it’s great that you all have a declass blog now, my late sister and your former friend and colleague, Eva, would have loved it. She always was an early adopter of technology.

    I don’t know if I will be able to attend the forum but I do have the date in mind.

  3. The description of Category 2 records does not include any mention of JFK Assassination Records. I wonder if this is because they don’t rank high in terms of research requests or if it is because the JFK Collection includes records from so many different agencies. A breakdown of where JFK records rank according to research requests would be helpful.

    I say this, not only as a published author working on a JFK book but also as a policy analyst. I would like to remind people working on the very worthwhile and overdue National Declassification Center project to remember that the single strongest declassification law in the U.S. Code is the JFK Assassination Records Act of 1992. This law, passed unanimously(emphasis added) by a Democratic Congress and signed into law by a Republican president, calls for the “immediate” declassification of all JFK assassination record in the government’s possession. OMB Watch, an independent watchdog group, called it a model of targeted declassification legislation. Countless historians working on the history of the Kennedy administration and the assassination agree. This law went a long way toward defusing criticism that the government was still keeping secrets around this most important and sensitive historical event. However, eighteen years later, a surprisingly large number of JFK assassination records remain secret. Since the dissolution of the Assassination Records Review Board (ARRB) in 1998, there has been no mechanism to ensure agency compliance with the JFK Records Act. Professor David Kaiser of the Naval War College and other scholars of the period have found a large number of JFK records that were never processed by the review board.
    I have sought other still-secret JFK records via FOIA litigation only to be stonewalled by the Central Intelligence Agency, which refuses to comply with the JFK Records Act. The CIA’s blatant defiance of the JFK Record Act is unfortunate, disturbing and needs to be addressed. In terms of public interest, such records need to be reviewed and released immediately. Even a half century after the event, there is no historical subject of greater enduring public interest than JFK’s assassination. The statistical anomaly that all JFK records do not come from one agency should not blind NARA to this obvious fact.

    I hope and trust that the National Declassification Center will take up the issue of still secret JFK assassination records. It is your mandate. If you avoid it, you will have failed.

    Thank you.
    Jefferson Morley
    Author, “Our Man in Mexico: Winston Scott and the Hidden History of the CIA”

    1. Thank you for your comment. In our initial culling of records, we chose the record group as the first logical grouping. We were guided by statistics from our reference unit on the most heavily requested records. We also took direction from the President’s memorandum of December 29, 2009, which requires us to eliminate the 400 million page backlog of records already accessioned into the National Archives by December 31, 2013. We are looking into way to work more effectively with agency records managers and NARA’s Lifecycle Management Division to ensure the timely declassification review and accessioning of permanent series of records. If there are series of permanent records still in agency custody, that contain JFK information, we would certainly be interested in seeing that they are accessioned as scheduled.

  4. Comments on the

    Draft National Declassification Center Prioritization Plan

    Submitted by:

    Brian W. Martin
    History Associates Incorporated
    June 24, 2010

    I am Brian Martin, president of History Associates Incorporated, a leading provider of historical and archival services to a wide range of clients across the United States and around the world. Throughout our nearly 30 years in business, we have conducted extensive historical research and analysis and provided archival and records management services in both classified and unclassified records held by various agencies and the National Archives and Records Administration (NARA). In our first decade of operations, History Associates managed declassification review projects under contract to the Department of Energy. Currently, much of our work regarding classified sources involves helping persons (both corporations and individuals) establish their legal rights and interests using historical evidence obtained by pursuing declassification and release of this information under the auspices of the Freedom of Information Act (FOIA).

    Given this background and experience, I have some appreciation for the enormity of the task President Obama has delegated to the National Declassification Center (NDC, or the Center).
    I also understand the solomonic responsibility you have to balance the competing aspects of your mission and particularly to set priorities for your work that take into account researcher interests and the likelihood of declassification. Thank you for providing this forum to comment on the draft plan and offer specific input regarding which records NDC should process first.


    My first comments and questions relate to the sources and methods (pun intended) that NDC is using to determine the degree of public interest in particular records. You mention (p.1) your intention to use such sources as “information about records requested in NARA research rooms, and by the public through the Freedom of Information Act, the Presidential Records Act and Mandatory Declassification Review provisions of E.O. 13526.” However, it appears (p. 3) that the primary, if not exclusive, source for outlining the top priorities on pp. 3-4 was “input from reference archivists at Archives II and the Office of Presidential Libraries.”

    While I have high regard for NARA’s professional archivists, I would like to know if this input was in the form of their impressionistic perceptions or quantitative data regarding pulls. The comment related to Category 2 records at the top of page 4 suggests you may have some aggregated quantitative data documenting researcher requests and the corresponding pulls, but in the past NARA has been unable to provide such data when requested in relation to its digitization programs. Is such statistical data now available? If so, how did you use it to develop these draft priorities and can you release the data for public review? As someone else commented at the public forum, seeing the underlying data would give us all greater confidence in your approach.

    Comprehensive data documenting researcher requests across NARA’s universe of collections would certainly be vital to determine the level of researcher interest in particular records. Indeed, such data—if it exists—should be given more weight than the impressionistic perceptions of archivists and researchers, no matter how familiar they are with NARA’s holdings. However, since such statistics would necessarily focus on NARA’s unclassified/declassified holdings, I suggest that an even better indicator of researcher interest in NARA’s classified holdings would be aggregate data indicating the level of researcher interest in particular classified records requested via the FOIA, Mandatory Declassification Review (MDR), and Presidential Records Act processes. Did the Center use such information to establish these draft priorities? If so, how? And can you make this data available to the public?

    Beyond these questions related to the sources of your information pertaining to the level of researcher interest, I believe that the method of applying whatever qualitative or quantitative information you have to establish priorities at the record group level is inappropriate. Record groups encompass too broad a range of organizational functions, subjects, record types, and declassification issues for NDC or the public to assign meaningful priorities at that file unit level. You acknowledge this in the draft plan when you say that “Each RG will be further subdivided to place each series or collection into one of the four categories.” ( p. 3) I recognize that providing thousands of series titles/descriptions would present a daunting volume of information for the public to sort through, but as you have already conceded, the series level is ultimately the appropriate level for assigning and managing priorities. I suggest that future iterations of NDC’s priority plan be presented to the public at the series level.

    When the application of your approach to balancing public interest and the likelihood of declassification results in
    90 percent of the records falling into prioritization Category 2, it appears that this methodology produces a distinction without a difference. It seems that the real prioritization challenge becomes how to differentiate the Category 2 records. On what basis have you selected the Category 2 records listed on page 4 as top priority, as opposed to the remaining records listed in Category 2 of Appendix A?

    Finally, given NDC’s deadline for clearing the backlog and the exemptions specified by the President in his December 29, 2009, directive regarding the implementation of E.O. 13526, it appears that NDC would place a high, if not the highest priority, on identifying and segregating those records believed to contain “information that would clearly and demonstrably reveal:
    (a) the identity of a confidential human source or a human intelligence source; or (b) key design concepts of weapons of mass destruction.” However, as I read it, you provide no indication as to how this prioritization activity is reflected in the draft prioritization plan. Please explain how you are balancing this activity to protect what you must with your efforts to release what you can in accordance with the priorities in the draft plan.


    Despite the questions raised above about NDC’s sources and methods used to compile its draft priorities, I want to offer some recommendations on what records should be the Center’s highest priorities, and which ones should be added to the list of backlog priorities. In doing so, I want to urge NDC to interpret the “degree” of researcher interest by taking into account the nature of that interest, as well as its extent. There are a significant number of professional historians and other researchers, including my colleagues at History Associates, who regularly request a wide range of records from NARA’s classified holdings on behalf of a variety of clients who require access to these records to establish their legal rights and interests, often within the context of a judicial process.

    Examples include:

    • Veterans seeking operational records to document exposures to hazardous materials, participation in intense fighting, or other events to pursue benefit claims or defend themselves in criminal matters.
    • Corporations and individuals disputing product liability claims involving weapons systems or other military hardware.
    • Corporations, governments, or individuals seeking to allocate environment remediation costs involving land or industrial operations where the federal government may have been involved as an owner, operator, or arranger.
    • Individuals, corporations, or governments involved in toxic tort matters related to alleged exposures to hazardous materials associated with military or defense industrial operations.

    Given that the purpose of prioritization is to determine which records the Center will release first, History Associates recommends that NDC give high priority to records needed to pursue timely justice for such individuals, organizations, and businesses and reduce the costs of legal proceedings for them and for the taxpayers. Often the records sought by these clients are administrative, transactional, technical, or personal in nature and are therefore of less broad public interest than the policy records typically requested by scholars, journalists, and public officials to analyze and hold our government accountable. The crucial question is how the Center will weigh that broad public interest against the relatively narrow, but arguably more immediate (and perhaps therefore warranting higher priority), interest of those seeking access to classified records to pursue their legal rights and interests.

    Granted, this issue adds another dimension to an already challenging prioritization task for which NDC has limited resources and time. Nevertheless, History Associates recommends that the Center look for information, perhaps available through Department of Justice (DOJ) or the Federal Judicial Center, to determine which series of NARA’s classified records are involved in currently pending federal legal proceedings—or in the alternative, proceedings over the last
    5-10 years. In addition, a careful review of recent and pending FOIA, MDR, and Presidential Records Act requests, and perhaps direct requests from DOJ and other agency lawyers will likely identify records requested in connection with legal proceedings that should merit high priority in NDC’s plan. The information from these sources will be far more extensive and precise than any impressionistic input NDC will receive from researchers, regardless of how much experience they have with NARA’s holdings.

    Nevertheless, since you have asked researchers to offer specific comments on the draft priorities, here are History Associates’ recommendations based on our range of experience.

    From the Category 1 list found in Appendix A, we recommend that NDC give highest priority to the following record groups:

    • RG 24 Bureau of Navy Personnel (Deck Logs)
    • RG 472 U.S. Forces in Southeast Asia

    Within the list of Category 2 backlog priorities found on page 4 of the draft plan, we recommend that NDC give highest priority to the following record groups:

    • RG 19 Bureau of Ships
    • RG 338 U.S. Army Operational, Tactical, and Support Organizations
    • RG 342 U.S. Air Force Commands, Activities, and Organizations

    We recommend that NDC add the following record groups from the Category 2 list in Appendix A to the backlog priority list:

    • RG 38 Chief of Naval Operations
    • RG 72 Bureau of Aeronautics
    • RG 74 Bureau of Ordnance
    • RG 77 Chief of Engineers
    • RG 156 Chief of Ordnance
    • RG 159 Inspector General (Army)
    • RG 175 Chemical Warfare Service
    • RG 181 Naval Districts and Shore Establishments
    • RG 326 Atomic Energy Commission
    • RG 343 NAVAIR
    • RG 344 NAVSEA
    • RG 402 Bureau of Naval Weapons
    • RG 428 General Records of the Department of the Navy
    • RG 430 Energy Research and Development Agency
    • RG 434 Department of Energy

    We recommend that NDC add the following record groups from the Category 4 list in Appendix A to the backlog priority list:

    • RG 71 Bureau of Yards and Docks
    • RG 112 Army Surgeon General
    • RG 291 Federal Property Resources Service
    • RG 346 Naval Ordnance Systems Command (NAVORD)
    • RG 544 Army Materiel Command
    • RG 546 Continental Army Command (CONARC)
    • RG 553 Training and Doctrine Command (TRADOC)

    As stated above, History Associates believes that it could make more informed and useful recommendations based on series level information rather than the inappropriate record group level information found in the draft plan.

    I appreciate the opportunity to provide input to the Center’s work and look forward to your response to the questions raised above.

    1. Thank you for your post and patience. We had hoped our final priority plan would be out by now. Since it is not, I thought I would address your comments. One of the suggestions you, and several others, made was to provide a greater level of detail in the plan. While our overall plan will remain at a high level, our annual work plans will address series level processing. In fact, we are waiting for the 2011 plans to be finalized and will issue them along with the larger plan. I hope to have them soon and will post links to both (the overall and 2011) plan on the blog. You also asked about how we prioritized…specifically if we had good quantitative data or if we relied on qualitative information from archivists, historians and others. For the most part we did use the “soft” data, but did have a 2008 reference “pull slip” study that guided us. You also asked about tracking FOIA/MDR requests and using that information as a prioritization factor. That suggestion fit nicely with a FOIA process improvement project I am leading and we were able to add fields to our FOIA tracking database to make that data reportable in the future. Another question you raised related to balancing efforts to protect sensitive information (especially Human Intel and weapons of mass destruction data) while releasing as much as possible. We address this as part of our inter-agency evaluation process. This is a method to triage series of records and recommend them for immediate processing or requiring some level of checking for the two categories spelled out in the President’s memo.
      With regard to specific priorities, we heard from a variety of groups and recognize that we need to balance processing of high-level policy type records with records that cover operation aspects of agency activity and often document individual rights and entitlements. Some areas where we will be focusing are operational records from US Forces in Southeast Asia and, in response to many requests from veterans, US Navy Deck Logs.
      Finally, thank you for your input. I hope that this dialog can continue. If you have any links to data sources on hot topics or types of requests, please let me know. I’m always looking for more data to share with my managers. Feel free to contact me on or off line.

  5. Hello,

    Could the prepared opening statements of the NDC panelists be posted, preferably in .pdf format please?
    Thank you.

    1. The Archivist’s opening comments have bee posted here: http://www.archives.gov/about/speeches/2010/6-23b-2010.html

      The webcast may be viewed here (click on the icon about 1/2 way down on the left): http://www.archives.gov/declassification/

      Prepared remarks from Sheryl Shenberger and Beth Fidler are copied below:

      The slogan of the National Declassification Center (NDC) is Releasing All We Can, Protecting What We Must. Today, I will discuss how we plan to work to make that slogan a reality.
      The NDC was established in order to facilitate the review and release of the optimum amount of information accessioned to the national Archives. We want to make available to the public the “historical timeline” of our government, and the collaborative effort inherent in the NDC is the most efficient way to make that happen.
      ? As the Archivist noted, the NDC was established in accordance with section 3.7 of EO 13526; its initial emphasis was established in the presidential memorandum: 400+M pages of material requiring processing and agency reviewing for potential release to the public.
      ? On 4 January 2010, less than a week after the President signed the EO, NARA formally established the NDC at Archives II at College Park. Of course, NARA had been on the forefront for planning for a possible NDC, advocating early on and prior to the new EO that the best way to deal with a large volume of records would be the collaborative approach advocated within the EO.
      What is the Initial Challenge for the NDC?
      Scope: 408M pages of classified Federal records over 25 years old and accessioned to NARA. Also, 4.6 million pages of Presidential materials that have been scanned and await referral clearance as part of the Remote Archives Capture (RAC)
      Classified Pages Accessioned Annually: 15M pages
      Classified Pages Available to the Public Annually: 11M pages
      Growth Rate of the Backlog: +4M pages per year
      Summary: With the previous level of resources in both the agencies and NARA, the backlog would NEVER clear using the current processes.
      How will the NDC meet these challenges?
      ? Through collaboration and cooperation: NARA entered into a partnership with the Lean Six Sigma Program (LSS) under the Department of Defense’s Deputy Chief Management Officer (DCMO) and through this LSS guidance, NARA established an interagency Program Management Team (PMT) that is working to improve and streamline NDC processes that will:
      ? Ensure the standardization and collection of declassification review related data between Federal agencies and the NDC.
      ? Develop a prioritization plan to focus declassification efforts on the records of the most interest to the public.
      ? Establish a Quality Assurance program that allows the NDC to check the quality of review and eliminate the 408 million page backlog at NARA.
      ? Create an interagency referral program that facilitates the review of Federal and Presidential records.
      Efforts are well underway to meet the presidential memorandum deadline and to establish a vital National Declassification Center.

      ? NARA is currently:
      • Reconfiguring existing workspace at Archives II to accommodate additional agency reviewers, and support review of special media records.
      • Intensively investigating, analyzing and then improving NDC declassification processes by making changes that will reduce backlogs and ensure quality reviews, without the need for multiple re-reviews.
      • Creating a library of approved declassification guides, available hard copy or in house on line for ease of searching. The NDC staff is testing a newly built Declassification Guide Web Application to centralize all equity recognition guides and make them accessible to reviewers working in the NDC.
      • Developing equity recognition training and certification for all reviewers. A total career path is envisioned that would include a number of courses aimed at agency equity identification, records handling, and review methodologies with a goal for certification as a professional declassification review officer.
      ? May 25-27, 2010 – The NDC held a three-day equity recognition training program to instruct reviewers on equities in the NARA backlog
      ? The NDC is planning:
      • Spring 2011 – An intensive 4 or 5 day interagency equity recognition training conference.
      • 7 Declassification training courses
      • 4 Web-based courses
      • 3 Instructor-led courses
      • One day course: Managing the Lifecycle of National Security Information Through Effective Records Management: A Course for Agency Records Managers and Security Specialists
      Specifically, what Changes are we testing and implementing?
      ? We are making changes to facilitate completing archival processing after declassification instead of during.
      ? Inserting decision points into the Quality Assurance (QA) process so records can bypass some or all of the QA steps.
      ? Embracing a risk management approach by instituting a sample review process in QA, focusing QA review on high risk collections.
      ? Expanding the Interagency Referral Center to allow more agencies access to their referrals
      These are major changes to our regular work process, and we will be constantly revisiting and testing them, checking with archivists, technicians, and agency personnel to fine tune them.

      How can you weigh in?

      The NDC website (www.archives.gov/declassification)
      A link to the NDC Blog http://blogs.archives.gov/ndc
      Via our meetings with agencies and the public to receive input and feedback on the operation of the NDC.
      Briefing agencies on the NDC and changes to the process

      NDC is a fine example of the elements of the Open Government Initiative;
      1. It is chartered with releasing historical information – an opening up of important historical documents.
      2. Its process, methods, and status are designed to be open and transparent, with results publically and openly available via regular reports.
      3. It is truly a collaborative effort, with NARA in the lead, bringing together all equity holders to facilitate efficient, responsible declassification review.

      The NDC initiative for 25 year old classified materials at the Presidential Libraries is the Remote Archives Capture or (RAC) Project. The RAC is a long standing program for the systematic referral of classified equities. Under the RAC Project we scan classified textual records from Presidential Libraries in the field and bring the images to a facility in the DC area so that they may be reviewed for declassification in a centralized location by all of the equity holding agencies. Declassification decisions are then returned to the Presidential Libraries and made available to the public. In most locations these releases have been made in textual form; however the Carter Library makes RAC releases available via an unclassified electronic system in their research room called the CREST system. Using CREST systems, we will make electronic releases available to the public at the other Presidential Libraries as they receive new decisions later this year. These CREST systems will assist Presidential Library archivists in making newly released documents available to the public in a quick and timely manner.
      We have scanned classified records for referral at the Truman through Carter Presidential Libraries and are currently scanning classified records from the Reagan administration. While we have received over 1 million pages in declassification decisions back from the RAC Project, we continue to have a backlog of 25 year old classified material which requires a declassification review. Under the auspices of the NDC, we have prepared a prioritization schedule for collections that agencies need to review in the next year taking into account both the age of the records and the high public interest of some of our Presidential collections. Our prioritization schedule for the first year focuses on the key National Security Council files at each of the Libraries and includes the following collections this year:
      • Truman – including all outstanding referrals. Collections include records from the Psychological Strategy Board, the President’s Secretary’s File, the National Security Council Files, and the Korean War File.

      • Eisenhower – all remaining referrals. Major collections include Papers of DDE as President (Ann Whitman File); Office of the Special Assistant for National Security Affairs; Office of the Staff Secretary; National Security Council papers; the Dulles papers; and the Council of Foreign Economic Policy.

      • John F. Kennedy – National Security Files including working files of McGeorge Bundy, Special Assistant to the President for National Security Affairs. This is the primary foreign policy file of the Kennedy White House.

      • Lyndon Baines Johnson – National Security Files including working files of President Johnson’s special assistants for national security affairs, McGeorge Bundy and Walt W. Rostow.

      • Richard Nixon Administration – Priorities include the classified referrals from the Erlichman and Haldeman Staff Member Office Files, the President’s Office File; and the Latin American Country Files

      • Gerald R. Ford – National Security Files including the files of President Ford’s National Security Advisers Henry Kissinger and Brent Scrowcroft.

      • Jimmy Carter – We have prioritized a portion of their National Security Files to include specifically the Brzezinski Materials; the Staff Secretary’s File; NSC Institutional Files, 1977-81; and Vice Presidential National Security Material for Walter Mondale.

      • And finally, we have prioritized a portion of the Kissinger materials scanned from his classified collection at the Library of Congress to include materials related to China.

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