Comments on the Draft Digitizing Plan

NARA's draft digitizing plan was issued for public comment for two months, starting on September 10, 2007. During that period we publicized the plan on our web site, via a Federal Register notice, and through emails to listservs and major stakeholder groups. In addition, we held a public forum (11 attendees), and staff meeting/teleconferences (about 140 participants).

We received about 500 separate comments from more than 300 respondents. The respondents primarily appeared to be individuals, although about 10 professional organizations and potential partners responded as well.

The overwhelming majority of comments were either implicitly or explicitly supportive of the plan for NARA to digitize and make available archival holdings to the public. However, important issues were raised, and we hope we have addressed many of them:

Nominations for records to be digitized (210 comments).
We received many messages from members of the public identifying specific records as a priority for digitizing. Approximately 90% nominated records of high genealogical interest, including naturalization, military service, pension, land, and immigration records; we also received a number of nominations for documents relating to African-American history, the Civil War, the War of 1812, and the Colonial period. A list of all nominations has been compiled and will be considered as we develop a registry of potential partnership materials.

Remote access to online materials should be free (22 comments).
Multiple respondents said that access to online materials should be free at all times. We edited our document to clarify that online access will be free in multiple NARA research rooms, instead of just the research room that serves the original documents. We also edited the plan to acknowledge that while we prefer free or very-low cost online access, we believe the trade-off between free online access or no online access is in the public interest.

How will partner copyright issues be addressed (15 comments)?
Multiple respondents asked questions about copyright, or stated that they opposed a partner being able to claim copyright on the digital copy. We worked internally to clarify our own policy, and then edited the document to include a principle that says the partner may not copyright the digital copies resulting from the partnership.

Online access should be affordable (5 comments).
Several respondents urged us to seek partners that would make the holdings available online at reasonable prices. We edited the document to indicate that we would consider affordability of partner services when reviewing proposals.

Five years is too long a period of proprietary rights for partner (5 comments).
Several respondents opposed the length of time during which the partner could charge for access and NARA could not make digital copies available for free except in its research rooms. We edited plan to acknowledge that we believe the trade-off between free online access or no online access is in the public interest, and to state that we believe that even during the proprietary period, free public access is significantly increased via our research rooms nationwide.

NARA should commit to making material available for free itself after five years (5 comments).
Several respondents expressed concern that we did not commit to making the digital copies available through our web site for free at the end of the proprietary period. We edited the document to indicate that in principle we are in favor of providing free access through our web site as quickly as possible, but that we are unable to categorically make this commitment without the funding to do so.

Use of term "non-exclusive" is not accurate since only one partner will be allowed to digitize original archival materials (4 comments).
Several respondents made this comment, which caused us to clarify our policy internally. We then edited the document to indicate that after five years (or agreed upon period of time), NARA may sell a complete, unrestricted set of the digital copies to another vendor.

NARA should not partner with any private, commercial, or non-governmental entity but should digitize archival holdings by itself (5 comments).
We did not alter the document in response to these comments. We believe the document sufficiently indicates that mass digitization is not possible without partners, and we believe that it is in the public interest to make such partnerships.

NARA should provide specific usage statistics to help partners identify materials (1 comment).
NARA does not have these statistics, but we will incorporate usage information into the registry of potential partnership material that we are developing, and will share that information with potential partners.

Measurement section is weak (5 comments).
We agree. We removed the whole section as it is really an internal NARA issue.

NARA is abdicating responsibility for the authenticity of copies digitized via partnerships (7 comments).
We believe we state very clearly in the document that we cannot guarantee authenticity of digital copies made by partners, and why. Our strategy is to digitize for access, not preservation. We simply do not have the resources to implement a program that would allow us to vouch for this authenticity. We did not alter the document.

NARA should maintain its commitment to providing archival expertise and records context (17 comments).
We agree. We edited the plan to further emphasize the importance of providing what we call "the archival view." We also added a fifth strategy that states that our own online catalog, by including descriptions of the digitized records, will serve as a hub to allow users to discover the materials regardless of who has digitized them and where they reside on the web. This fifth strategy also should alleviate concerns about the expense of users having to subscribe to multiple services to see if a certain NARA document has been digitized.

NARA may not have sufficient technical, logistical, or management infrastructure to support mass digitizing projects or to maintain the digital copies for the long-term (15 comments).
We agree that this is a known risk, and are undertaking multiple activities to improve this infrastructure, including a business process reengineering study. We believe that this information is out of the scope of the document.

NARA does not have an adequate process in place to make corrections or updates to partner images and data (7 comments).
We agree. We will explore this issue for existing partnerships, and will make this a requirement of new partnerships.

NARA imaging specifications are not adequate (1 comment).
We believe they are adequate for access.

NARA's 2004 Technical Guidelines for Digitizing Archival Materials for Electronic Access define two levels of information capture - our recommended level and an alternative minimum level. The recommended information capture levels cited in NARA's 2004 Technical Guidelines are all cited as "minimum" requirements. The recommended level exceeds the minimum requirements recommended by other organizations for the digitization of textual records - such as the Digital Library Federation's Benchmark for Faithful Digital Reproductions of Monographs and Serials - http://www.diglib.org/standards/bmarkfin.htm).

Also, NARA's recommended information capture levels have been adopted by many organizations as being appropriate for preservation reformatting of many types of records. The Digitization Standards Working Group of the National Digital Strategy Advisory Board (NDSAB), a group of approximately ten Federal agencies and outside technical experts, has decided to use NARA's 2004 Technical Guidelines as the basis of their work (information is to be available soon at www.digitizationguidelines.gov).

Many other organizations use comparable requirements.

NARA's minimum information capture levels are appropriate for providing access and high-quality reproductions of the original records. The minimum requirements are based on NARA's 1998 Guidelines for Digitizing Archival Materials for Electronic Access (http://www.archives.gov/preservation/technical/guidelines.html), used were for NARA's pilot Electronic Access Project. We estimate the minimum information capture levels meet 90% of all reproduction requests.

Also, the minimum requirements cited in NARA's 2004 Technical Guidelines are matched to the Transfer Instructions NARA has issued for Federal Agencies that are scanning permanently valuable records - http://www.archives.gov/records-mgmt/initiatives/erm-products.html.

The document does not address records management of the digital copies (2 comments).
We agree. We did not edit the document because we believe this is an internal issue.

NARA should not destroy originals (2 comments).
We agree. It is not NARA's intention to do so. We have clarified the document.

NARA should not restrict access to the original documents, even after they are scanned (2 comments).
This document does not change NARA's existing policy on this issue. The Code of Federal Regulations, in 36 CFR 1254.20, says that "Researchers must use microfilm copies or other alternative copies of documents when available, rather than the original documents." Exceptions are granted when the copy is illegible or fails to reproduce significant information conveyed by color in the original.

The document is not detailed enough to be called a plan (2 comments).
We agree, and have changed "plan" to "strategy. " In addition, we removed some of the more detailed information that, while useful in developing and reviewing the document, is too detailed for the document's intended purpose. For example, we removed sections that identified in detail digital harvest, existing partnership, and NARA-led project information. We have placed these on the NARA web site and referenced them in the document.

Many very detailed, specific questions about processes and standards; many editorial suggestions.
Where possible and appropriate, changes have been made or details added. However, many of the questions were extremely detailed, and relate to internal NARA processes. In these cases, changes were not made to plan.