Public Comments Submitted by Robert Hammond on February 3, 2023
See properly formatted presentation at:
https://www.documentcloud.org/documents/23597589-centrally-funded-foia-portal-and-case-managements-platform-for-all-federal-agencies
Centrally Funded FOIA Portal and Case Managements Platform for all Federal Agencies Hyperlinked Outline
Hyperlinked Outline 2
Preface 3
Email to Chief FOIA Officers & FOIA Advisory Committee 4
Hammond Public Comments - Sample 9
Metadata for Search Engines 11
Preface
* This presentation is to compel needed change.
* I fear that the federal government may be going down the path of numerous
FOIA portals/case management platforms with disjointed procurement, costing
we taxpayers unnecessary premiums for systems that will still have to program
to the FOIA.gov draft API.
* Herein, I put forth my idea for a centrally funded FOIA portal and case
management platform for all federal agencies, along with my suggestion for an
agency with the expertise to develop such an application. Others may have
different approaches.
Email to Chief FOIA Officers & FOIA Advisory Committee
From: dod.foia.pa@gmail.com
Sent: Thursday, January 12, 2023 5:44 PM
To: dod.foia.pa@gmail.com
Subject: FW: $$ Centrally funded FOIA portal and case management platform for
all! $$
Greetings Chief FOIA Officers, FOIA professionals, media, non-profit FOIA
advocacy groups, GAO, interested parties!
$$ Please see my suggestions below for a robust centrally funded FOIA portal
and case management system for the entire federal government to join. This is
particularly important for those agencies using FOIAonline, which will be
sunset in 2023. $$
I fear that the federal government may be going down the path of numerous
FOIA portals/case management platforms with disjointed procurement, costing
we taxpayers unnecessary premiums for systems that will still have to program
to the FOIA.gov draft API.
Please share this with your leadership. You may provide comments
(non-attribution) to the FOIA Advisory Committee
(foia-advisory-committee@nara.gov), DOJ OIP Director Bobby Talebian and DOJ
Associate Attorney General Vanita Gupta [Bobby Talebian email]; [Vanita Gupta
email]
You may ask that your comments be provided to the full Chief FOIA Officers
Council – no attribution if you wish.
With my deep respect,
Robert Hammond
From: dod.foia.pa@gmail.com
Sent: Friday, January 6, 2023 2:20 PM
To: [Joo Chung]; [George Duchak]
Cc: [Lewis Oleinick];'FOIA Advisory Committee' ; dod.foia.pa@gmail.com
Subject: DLA + FW: FOIA.gov Program Records [Centrally funded FOIA portal and
case management platform for all]
Ms. Chung (DOD Chief FOIA Officer) and Mr. [Dr.] Duchak (DLA Info Ops),
Please see attached and below suggesting that DLA might build a robust FOIA
portal and case management system for the entire federal government to join.
Best of breed. This may seem like a burden, but DLA uses FOIAonline as do
many other DOD entities, such that DLA must already be working on a
FOIAonline replacement. This may be a matter of scaling to accommodate all.
I also believe that it is nuts to have a rudimentary FOIA.gov portal to which
all FOIA case management systems must interface. No criticism of DOJ; just
that DLA is the preeminent major automated information system
development/maintenance entity in the federal government. No one does it
better!
DLA has also integrated records management and contracting into its FOIA
process withing Info Ops, enabling DLA to answer simple FOIA requests in two
days on average. No one else comes close. Perhaps DOD may work with OMB and
DOJ on initial funding.
See The FOIA Improvement Act of 2016:
m(1) The Director of the Office of Management and Budget, in consultation
with the Attorney General, shall ensure the operation of a consolidated
online request portal that allows a member of the public to submit a request
for records under subsection (a) to any agency from a single website. The
portal may include any additional tools the Director of the Office of
Management and Budget finds will improve the implementation of this section.
(2) This subsection shall not be construed to alter the power of any other
agency to create or maintain an independent online portal for the submission
of a request for records under this section. The Director of the Office of
Management and Budget shall establish standards for interoperability between
the portal required under paragraph (1) and other request processing software
used by agencies subject to this section.’.
With my deep respect,
Robert (Bob) Hammond
Copy to GAO, et. al.
From: foiacompliance@gmail.com
Sent: Friday, January 6, 2023 1:10 PM
To: dod.foia.pa@gmail.com
Cc: 'FOIA Advisory Committee' ; foiacomplaince@gmail.com
Subject: FW: FOIA.gov Program Records [Centrally funded FOIA portal and case
management platform for all]
Greetings Chief FOIA Officers, FOIA professionals, media, non-profit FOIA
advocacy groups, GAO, interested parties!
Particularly with FOIAonline going away in 2023, I believe DOJ/lead agency
should budget for and centrally fund a robust FOIA portal and case management
system now as discussed below. This is the best use of scarce tax dollars and
will significantly improve FOIA processing and reporting. DOJ may select an
agency to lead development/maintenance which has major automated information
system development as a core competency (Defense Logistics Agency, for
example, if they can be convinced to do it outside of the Defense Working
Capital Fund. DOD accounts for more than half of federal discretionary
spending each year with commensurate FOIA case volume and with many DOD
components needing a replacement for FOIAonline anyway.).
You may make your thoughts known to DOJ and the FOIA Advisory Committee –
non-attribution.
Also, for agencies using FOIAonline, please plan to preserve every unique
data element for each FOIA request, which constitutes unique FOIA case
processing records that must be preserved. See my public comment, “Preserve
FOIAonline Records.” This is another reason why a robust, centrally funded
FOIA portal and case management system makes sense to me going forward –
global preservation of records with centralized released records search at no
or minimal costs to the agencies.
With my respect,
Robert Hammond
From: foiacompliance@gmail.com
Sent: Friday, January 6, 2023 7:21 AM
To: 'FOIA Advisory Committee'
Cc: foiacompliance@gmail.com
Subject: FOIA.gov Program Records
FOIA Advisory Committee,
While my highest priority for the Technology WG is preservation of unique
FOIAonline case processing records, I believe that the Committee may want to
review FOIA.gov program records to ascertain the functional requirements,
etc. to see what we taxpayers were supposed to get for our money and what
improvements may be needed to make FOIA.gov a robust FOIA portal and case
management system meeting the needs of requesters and agencies alike and
useable by all. (See Muckrock.com and FOIAonline functionality.) This is
essentially the statutory mandate.
Instead, FOIA.gov has virtually no capability and drives costs for the entire
federal government by requiring agency FOIA platforms to program to a draft
Application Program Interface (API) to exchange only basic data regarding
FOIA requests and appeals. And, as I have documented, FOIA.gov does not even
have visibility of agencies not submitting quarterly data (e.g., NARA) such
that the statistical data in FOIA.gov is [] unusable for any purpose.
I seek records in the attached FOIA request as a starting point to see how
FOIA.gov may be improved to serve the interests of the agencies and requester
community alike. Should FOIA.gov be coupled with commercial case management
software, such software should include a government-wide license or be listed
on a GSA IT schedule where agencies may purchase seats/licenses at a
significantly reduced cost. I fear that the federal government may be going
down the path of numerous FOIA portals/case management platforms with
disjointed procurement, costing we taxpayers unnecessary premiums for systems
that will still have to program to the FOIA.gov draft API. I note further
that DOJ is not very good at developing major automated information systems
– just because it is not among their core competencies. Perhaps FOIA.gov
would be better managed by another agency with expertise in system
development as a core competency and with a configuration management board to
approve and prioritize systems changes. There are various ways to charge
agencies if DOJ/lead agency is unable to secure stand-alone funding
(preferred approach).
Congress already approved development of a centralized FOIA portal, but
without funding. It is up to the lead agency to seek such finding in budget
requests. Given the many written public comments that I have submitted
documenting massive false/errant FOIA reporting, I believe that Congress will
support funding for a central FOIA portal/case management system that entices
federal agencies to use it instead of each developing something new.
--/
REDACTED. Thank you for your service to our nation.
I look forward to reviewing my many public comment recommendations with the
appropriate Committee working groups and supporting the Committee in any way
I can.
Good luck!
Robert (Bob) Hammond
Hammond Public Comments - Sample
#
Hammond Public Comments. Document Cloud Alphabetical
(25 per page on web, not alphabetical)
https://www.documentcloud.org/app?q=%2Buser%3Arobert-hammond-106693%20
1
2022- 2024 FOIA Advisory Committee Bylaws - Recommended Changes
2
2022- 2024 FOIA Advisory Committee Inaugural Meeting. DOJ OIP OGIS Grossly
Underfunded
3
All Panelist Chat to June 9 2022 FOIA Advisory Committee Meeting. OGIS DOJ
Funding + Miss
4
Centrally Funded FOIA Portal and Case Management Platform for All
5
Combining Appeals Across FY NARA Massive FOIA Fraud
6
Comments to Unlawful Chief FOIA Officers Meeting of November 17 2021
7
DOD FOIA Misconduct Part IV. FY 2018 Appeals Disappeared + DOJ OIP & OGIS
Underfunded, Thus Ineffective
8
DOD FOIA Misconduct Part V. Navy FY 2018 Appeals Dispositions Bases Not
Reported
9
DOD Massive False FOIA Reporting. Part 1. Letter to SECDEF, Complaint to DOJ
OIG
10
DOD MASSIVE FALSE REPORTING PART II + Still Interested Abuse. Updated July
27, 2022
11
DOD Massive False Reporting Part III. 5-year Late Acknowledgements Unusual
Circumstances Abuse +
12
DOD’ Cites Change to CFR 32 CFR part 286.4 as Unlawful Basis for Omitting
OGIS Mediation Rights
13
DOJ OIP (Inaccurate) CFO Report Assessment 2022
14
DOJ OIP Compliance Inquiries
15
DOJ OIP Improper and Unlawful Standard Glomar Responses With Implicit (b)(1)
& (b)(7)
16
Failure - FOIA Compliance Oversight & Funding. Part 2. No Joking Matter
17
FOIA Advisory Committee December 1, 2022 Meeting Hammond Comments
18
FOIA Line-Item Budgets Now. Let the citizens be heard. Retire FOIA Bob.
19
FOIAonline - Recommended System Changes
20
Foreseeable Harm Standard Vanita Gupta. November 3, 2022 CFO Meeting
21
Foreseeable Harm Standard. DOJ OIP Misinformation + Navy Misconduct and
Idiocy?
22
Hammond Questions Comments for September 8 2022 Meeting. OGIS and DOJ OIP
Lack of Funding w.attach1
23
Hammond Recommendations and Chat Comments to 4.7.2022 FOIA Advisory Committee
Meeting
24
HOT! Semo OGIS. Budget Numbers do not Comport w. NARA Published Budgets!
25
Individualized Tracking Numbers. NARA Fraud. Hatch Act Violations
26
Mandatory Right to OGIS Dispute Resolution - OGIS Malfeasance 20220616
27
Moot Appellate Determinations
28
NARA FOIA & Financial Malfeasance $789,730 + Alteration of Records and Loss
of Public Trust
29
NARA FY 2022 Data Stripped From FOIA.gov
30
NARA, PLEASE FUND OGIS!! (PART 1). Robert Hammond September 9, 2021 Speaker
Notes
31
Navy FOIA Fraud - False Reporting, Refusal of FOIA.gov, etc.
32
Navy FOIA Misconduct. No IDA Letter & Fee Abuse. DON-NAVY-2023-000588
33
Navy FY 2018 FOIA Appeals Disappeared
34
OGIS & DOJ OIP Misstate Recommendation to Post FOIA Logs - Why
35
OGIS & Navy FOIA Fraud. Mediation, ECDs, False FOIA Reporting
36
OGIS Funding and Case Accountability Logs
37
OGIS Negligence Generally & Improper June 29, 2022 FOIA Meeting
38
OGIS Posting Policy for Public Comments
39
Posting FOIA Logs. Tech Committee Recommendation #2. FOIA Ombudsman
Inaccurate Citation
40
Preserve FOIAonline Records + Decertify FOIA.gov + Audit NARA + Post FOIA
Logs
41
QUESTIONS for June 29, 2022 OGIS Annual FOIA Meeting v2
42
Response to Hon. David S. Ferriero June 10 2021 Comments to FOIA Advisory
Committee
43
Sample FOIA Template to Combat Agency Misconduct 20220616
44
Senate-hearing-on-foia.-dojs-lack-of-enforcement-malfeasance-open-the-government-statement.v2
45
Senator Grassley - DOJ OIP'S Position Doesn't Pass the "Common Sense Test"
46
Senators Unite to Slam FOIA Compliance + POGO
47
Subpoena Threat and Congressional Demand for OGIS to Release Records. OMB
Kills Recommendations
48
Sued into Oblivion. Foreseeable Harm Standard
49
Violations of the ADA in FOIA Redactions, Simple Solution
50
Expedited FOIA Processing Malfeasance - NARA FY 2020 & FY2021
Metadata for Search Engines
Because NARA is no longer posting PDF documents with their metadata, the
metadata for search engines is shown here.
Expedited FOIA Processing Malfeasance - NARA FY 2020 & FY2021
National Archives Administration Performance Budget,
Alina Semo,
Archivist of the United States,
Bobak Talebian,
Broken FOIA,
Chief FOIA Officers Council,
Chief FOIA Officers Report,
Defense Health Agency FOIA,
DEPARTMENT OF JUSTICE GUIDE TO THE FREEDOM OF INFORMATION ACT,
Department of Justice Office of Information Policy,
DOJ FOIA,
DOJ Office of Information Policy,
DOJ OIP,
FOIA Administrative Appeals,
FOIA Advisory Committee,
FOIA Advocate,
FOIA Annual Reports,
FOIA COMPLIANCE INQUIRIES,
FOIA compliance,
FOIA Deliberative Process,
FOIA exemption (b)(5),
FOIA Exemption (b)(6),
FOIA Exemption 5,
FOIA Exemption 6,
FOIA False FOIA Reporting,
FOIA Improvement Act of 2016,
FOIA Ombudsman,
FOIA Privacy Exemption,
FOIA Proactive Disclosures,
FOIA STATUTE,
FOIA Sunshine Week,
FOIA,
FOIA.gov,
FOIAonline.gov,
Freedom of Information Act,
help with FOIA,
NARA Unauthorized Disposition Federal Records,
NARA,
Navy FOIA,
Office of Government Information Services,
OGIS Dispute Resolution,
OGIS FOIA Annual Open Meeting,
OGIS mediation,
OGIS,
Quarterly and Annual FOIA Reports,
Records Management Oversight and Reporting Program,
U.S. Second Open Government National Action Plan,
YOUR RIGHT TO FEDERAL RECORDS,
32 CFR §286.6 Preservation of records,
32 CFR PART 286 - DOD FREEDOM OF INFORMATION ACT (FOIA) PROGRAM,
36 CFR § 1230.3,
44 U.S. Code § 3106 - Unlawful removal destruction of records,
Defense Health Agency FOIA,
NARA Unauthorized disposition,
Unauthorized disposition or destruction of records,
Unlawful or accidental destruction of records,
TAGS
NARA FOIA Request and Appeals Case Processing Logs,
Agency FOIA Request and Appeals Case Processing Logs,
your right to federal records,
department of justice office of information policy,
44 U.S. code§ 3106 - unlawful removal destruction of records,
help with FOIA,
NARA,
36 CFR § 1230.3,
FOIA sunshine week,
OGIS,
FOIA ombudsman,
FOIA compliance inquiries,
freedom of information act,
FOIA proactive disclosures,
unauthorized disposition or destruction of records,
department of justice guide to the freedom of information act,
national archives administration performance budget,
32 CFR part 286 – DOD freedom of information act (FOIA) program,
FOIA Exemption 6,
Office of Government Services,
FOIA compliance,
FOIA exemption (b)(5),
32 CFR §286.6 preservation of records,
FOIA false FOIA reporting,
FOIA privacy exemption,
Foia administrative appeals,
FOIAonline.gov,
Navy FOIA,
unlawful or accidental destruction of records,
OGIS FOIA annual open meeting,
FOIA,
quarterly and annual FOIA reports,
DOJ FOIA,
FOIA statute,
Defense Health Agency FOIA,
FOIA deliberative process,
Chief FOIA Officers Report,
broken FOIA,
U.S. second open government national action plan,
FOIA advocate,
DOJ Office of Information Policy,
FOIA Advisory Committee,
Bobak Talebian,
Alina Semo,
FOIA.gov,
archivist of the united states,
OGIS dispute resolution,
NARA unauthorized disposition,
FOIA exemption (b)(6),
OGIS mediation,
Chief FOIA Officers Council,
FOIA improvement act of 2016,
NARA unauthorized disposition federal records,
Centrally Funded FOIA Portal and Case Management Platform for all Federal
Agencies,