Public Comments Submitted by Robert Hammond on January 14, 2023

NARA OGIS and DOJ OIP,

Please post the attached public comment to both the FOIA Advisory Committee
and the Chief FOIA Officers Council websites, “Expedited FOIA Processing
Malfeasance - NARA FY 2020 & FY2021.” I m providing this in MS Word, PDF,
and HTML

This presentation documents NARA’s:
       * Failure to process expedited FOIA requests ahead of others.
       * Massive false FOIA reporting plus second grade math.
       * NARA routinely combining FOIA requests and appeals under single
tracking numbers (sometimes 40+).

--/
As to NARA’s new Public Comment Form and Posting Policy, this appears to be
a violation of law and it is unworkable.

The new form only allows text comments, whereas Word and PDF may also be ADA
compliant and contain considerably more formatting and content such as
hyperlinks and bookmarks to assist ADA challenged persons and others in
navigating a presentation. The move away from PDF for example may have
nothing whatsoever to do with ADA compliance. The outcome is that text only
documents eliminate metadata that makes the presentations discoverable. In
addition to accessibility checkers in MS Word and Adobe Acrobat, there are
numerous accessibility checkers.

See my prior public comment, OGIS Posting Policy for Public Comments 47 pages
- Robert Hammond - Jun 28, 2022 at OGIS Posting Policy for Public Comments -
DocumentCloud
https://www.documentcloud.org/documents/22071916-ogis-posting-policy-for-public-comments
.

NARA’s new Posting Policy for Public Comments | National Archives
https://www.archives.gov/ogis/about/public-comments-policy is similarly
unlawful and adds new unlawful requirements, including that “Comments
submitted to the FOIA Advisory Committee or for the OGIS Annual Open Meeting
should pertain to the specific topics covered at that public meeting” and
that “For the OGIS Annual Open Meeting, we will accept written comments
only 30 days before and 30 days after a scheduled meeting.” This is
nonsense. NARA cannot adjudicate one public comment within 30 days, and I
will be providing at least 51 to date. I will be sending those soon to give
NARA a head start. NARA and DOJ OIP must promptly respond regarding any
public comment that will not be posted.

I very much want to work with OGIS and DOJ OIP to improve FOIA processes.
Please change your public comments posting process.

To comply with the new Public Comment Form, I will be entering this email
into the test box of the new form and consider my presentation delivered and
compliant.

Thank you.

With my deep respect,

Robert Hammond
Copy to:
NARA OIG
GAO
FOIA Compliance Distribution