Part I, section 1.1 "By 2019, Federal agencies will manage all permanent electronic records in an electronic format" seems like looking for trouble, given the significant reduction in funding for ERA, and the general lack of reality in digital preservation for the REALLY, REALLY long term (as opposed to the next human generation).



Part II, Section A3.1 states "By December 31, 2013, NARA will produce a comprehensive plan in collaboration with its stakeholders to describe suitable approaches for the automated management of email, social media, and other types of digital content, including advanced search techniques." Isn't that what NARA's Office of Applied Research (http://www.archives.gov/applied-research/) has already done?



Part II, Section A5 seems to imply NARA will share control over the records in the cloud with the agencies. A divided control system seems fragile and prone to contention. Do others read it that way?



And I wonder about the wisdom of Part II, Section C2 "... expanding the number of permanent record series in the GRS [General Records Schedules] to reduce the scheduling and appraisal burden on agencies." It seems to me this trades off an old problem (the scheduling and appraisal burden) for a new one:  more permanent records to preserve. And they will be digital, worse yet.



Best regards,



Fred

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Frederic J. Grevin

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