On 30 August 2012, Mr. Paul Wester (NARA's Chief Records Officer), replied to my earlier posting on David Ferriero's behalf at his blog. http://blogs.archives.gov/aotus/?p=4396
First, Mr. Wester states "ERA has moved into its operations and maintenance phase, and we are working with our new contractor to maintain the system in an operational mode and make adaptations and corrections to the system to allow it to meet existing and emerging requirements for the system. Having the long-range target of 2019 will give us time to ensure that ERA and our information systems supporting records are full able to meet that challenge."
This doesn't begin to address the system replacement issues over the very long term:  permanent records won't go away in 2020 and, in the current political environment where the only good government is no government or, at best, "small government" (whatever that is), the political support required to get funding for an entirely new system is improbable. And even that assumes funding will be provided in the interim to support "[the] ... operational mode and make adaptations and corrections to the system." I remain skeptical.
Second, Wester says "We anticipate that agencies will be able to develop plans that improve their processes to encourage the use of sustainable formats for their record materials." Whether the federal agencies as a whole are capable of developing such plans at all, of developing them within the time constraints of the Presidential Directive, and of developing them without additional funding, is debatable. There are all too many 'ifs' here.
Third, Wester states "While the Office of Applied Research has already done a significant amount of work in this area, we want to work more with agencies on this goal to identify other factors that keep the existing plans from being widely adopted and implemented." This implies OAR has not done such work (it has a long-standing relationship with, amongst others, the Army Research Laboratory) and is not capable of doing it. Which group at NARA is competent to administer this project, if not OAR? Why not build on what you've already got, rather than tearing it down?
Fourth, Wester's response to my question about shared control over records in the cloud is "NARA and its partners across the government will address this issue through the feasibility study that the Directive describes." Has NARA really not heard about other such feasibility studies, such as the 2012 "Pilot Texas Cloud Offering:  Lessons learned" by the Texas Department of Information Resources (http://www.dir.texas.gov/SiteCollectionDocuments/Texas.gov/ptco.pdf), and the adoption of the Tessella system by the National Archives of the UK? (see http://www.tessella.com/2011/04/press-release-the-national-archives-and-tessella-win-queens-award-for-enterprise/)
Finally, The statement that "Increasing the number of permanent series in the General Records Schedule (GRS) will, as you note, reduce the scheduling burden on agencies. Agencies can then use our pre-accessioning program to not worry about the preservation challenges" simply does not address the issues created by increasing the burdens of a greater number and larger volume of permanent records. As a one-time archeologist, I applaud the intent. As a records and information manager who has to deal with reality (few and fewer resources; budgets decreasing every year; unwillingness on the part of users to provide sufficient metadata; and plenty more), I think this approach is not rooted in reality.
However, I hope to be proven wrong, and wish the National Archives the very best of success in its reforms of the practice of records and archives management.
Fred Grevin
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