Public Comments Submitted by Robert Hammond on August 28, 2021 - OGIS & DOJ Web Counters & FOIA Systems. May 12, 2021 FOIA Meeting Comments

from: Robert Hammond

to: foia-advisory-committee@nara.gov

date: Aug 28, 2021, 9:26 PM

subject: Attached Public Comments for FOIA Advisory Committee OGIS & DOJ Web Counters & FOIA Systems.

Please post attached.

Thx.
Robert Hammond

Attachment - FOIA Advisory Committee August 28, 2021.docx

“OGIS & DOJ Web Counters & FOIA Systems. May 12, 2021 FOIA Meeting Comments”

by Robert Hammond

Shout out to OGIS & DOJ OIP – I need your help.

Thank you for giving me an opportunity to participate.

“It is better to light one small candle than to curse the darkness.” That is what I am trying to do. I need your help. I am asking for your help.

I want to give a shout out to OGIS and DOJ OIP regarding their essential missions. Ms. Semo said that one of the roles is to keep the process fair.  That is an essential safeguard. DOJ OIP, through complaince inquiries has a similar role. I read your work products. They are excellent. As Ms. Semo has noted, OGIS (and OIP) are severely understaffed compared to their vast responsibilities.

For my part, I plan to write a letter to the appropriate Congressional committees emphasizing the importance of your work and the need for more resources. FOIA is an essential government function.

As to backlogs, I would rather have a response take longer but be thorough than have it quicker. As I told Ms. Semo in an email, as a career finance guy (in addition to Information technology, federal procurement, and logistics), I can tell you that in the budget world doing more with less gets you less. Reporting backlogs is not necessarily a bad thing if you can show that you are ”boiling the ocean” with your limited staff but still can’t keep up. However, making the workload “go away,” or not fully/accurately investigating submissions are not appropriate.

SHOUT OUT TO Michael Morisy, MuckRock,  & “release to one, release to all” solved.

Though Mr. Morisy is not representing MUCKFOCK in this Committee, I want to give a shout out to MUCKROCK. The MUCKROCK FOIA portal is excellent for the requester. It solves ‘release to one, release to all” issue by allowing requesters (such as the media) to embargo or shield requests from public view for as long as the requester desires. It allows screen names to protect shy requesters and it has a robust database of where to send FOIA requests for both federal and state agencies. For the Requester Community, it is better than FOIA.gov (in my view) in that it incorporates state entities as well. MuckRock also allows a requester to set triggers for automatic follow-ups preventing the dreaded “still interested” queries. It preserves all correspondence and records released in a single location. On top of that, MUCKROCK facilitates collaboration among requesters on specific projects and publishes useful articles to assist Requesters. Great, responsive staff.

SHOUT OUT TO EPA & FOIAonline Configuration Management Board.  

In my view, FOIAonline is the gold standard for FOIA portals and case management systems. I studied the Agency User Guide and have used FOIAonline extensively for years, along with many other federal FOIA portals. I am working with the FOIAonline Configuration Management Board on suggested systems changes to enhance the application. I would like a public demonstration of FOIAonline at a future meeting and suggest that agencies consider their own FOIA portal/case management system capabilities and costs compared to the Shared Costs for FOIAonline’s mature, robust capabilities. FOIA.gov integration is another good reason for Agencies to join on to FOIAonline and let them do the one-time integration to FOIA.gov for all supported agencies. Economies of scale and lower per capita costs for all. (Happy taxpayer, great functionality.) I was disappointed to see DOJ split off from FOIAonline with FOIA STAR, and without any notification to users or data transition prior to implementation.

I would invite briefings of FOIA STAR and FOIA.gov at future open meetings, to include functional requirements and lifecycle costs, as matters of significant public interest.

FOIA.gov

Single FOIA Portal. A quick, easy cost-effective initial win is to simply link to the agency’s own FOIA portal in lieu of or as an interim solution to the costly API overlay. I would much rather deal directly with the Agency’s FOIA portal (PAL, etc.) than FOIA.gov, which cannot offer any functionality not already resident in the Agency’s FOIA portal/case management system. The FOIA.gov portal is very rudimentary for requesters, lacking considerable functionality resident in FOIAonline for example. I have read FOIA.gov Developer resources (www.foia.gov/developer/) and FOIA.gov Draft RESTful HTTPS API Spec (www.foia.gov/developer/agency-api/).

RECOMMENDATION. Visitor Counters on NARA and DOJ FOIA websites.   

I would like to see visitor counters on NARA OGIS and DOJ OIP websites that are visible to the public. Many are free. Perhaps DOJ and OGIS already have them, but not publicly viewable. I would recommend differentiating unique visitors and (if feasible) distinguishing by domain (.edu, .gov, .mil, .com). It is important to know who is accessing published reports such as the FOIA Advisory Committee term reports, etc., to see if they are reaching the target audience, and then tailor meetings, etc., to meet the user community interests. While DOJ OIP and NARA OGIS certainly need this information, I believe that it would be of interest to the public as well.

Thank you.

With my respect,

Robert Hammond