Information Management: Challenges in Managing and Preserving	 
Electronic Records (17-JUN-01, GAO-02-586).			 
                                                                 
Agencies are increasingly moving to an environment in which	 
electronic rather than paper records. Because electronic records 
provide comprehensive documentation of essential government	 
functions and provide information necessary to protect government
and citizen interests, their proper management is essential.	 
Further, the preservation of significant documents and other	 
records is crucial for the historical record. Responsibility for 
the government's electronic records lies with the National	 
Archives and Records Administration (NARA). NRA completed an	 
assessment of the current federal record keeping environment in  
2001 which concluded that although agencies are creating and	 
maintaining records appropriately, most remain unscheduled, and  
records of historical value are not being identified and provided
to NARA for archival preservation. Although NARA plans to improve
its guidance and to address technology issues, its plans do not  
address the low priority generally given to records management	 
programs, nor the issue of systematic inspections. Recognizing	 
the limitations of its technical strategies to support		 
preservation, management, and sustained access to electronic	 
records, NARA is planning to design, acquire, and manage an	 
advanced electronic records (ERA) system. However, NARA is behind
schedule for the ERA system, largely because of flaws in how the 
schedule was developed. Further, to acquire a major system like  
ERA, NARA needs to improve its information technology management 
capabilities.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-586 					        
    ACCNO:   A03645						        
  TITLE:     Information Management: Challenges in Managing and       
Preserving Electronic Records					 
     DATE:   06/17/2001 
  SUBJECT:   Records management 				 
	     Electronic government				 
	     Archives						 
	     Information resources management			 
	     Information technology				 

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GAO-02-586
     
A

Report to Congressional Requesters

June 2002 INFORMATION MANAGEMENT Challenges in Managing and Preserving
Electronic Records

GAO- 02- 586

Letter 1 Results in Brief 2 Background 3 NARA Is Responding to Challenges of
Electronic Records

Management 15 NARA?s Effort to Acquire Advanced Electronic Archival System

Faces Risks 23 Conclusions 32 Recommendations for Executive Action 33 Agency
Comments and Our Evaluation 33

Appendixes

Appendix I: Objectives, Scope, and Methodology 37

Appendix II: Approaches to Archiving Electronic Records Provide Partial
Solutions 39

Appendix III: NARA?s Electronic Records Guidance Has Evolved 57

Appendix IV: Agencies Are Managing Large Volumes of Important Electronic
Records 66

Appendix V: Comments from the National Archives and Records Administration
70

Glossary 75 Table Table 1: Timeline for ERA Program 25 Figures Figure 1:
Removable Hard Drives and Backup Devices Used by

Independent Counsel Staff 7 Figure 2: Master Copies of Electronic Records in
NARA?s Archives 8

Figure 3: OAIS Model and Its Components 15 Figure 4: Sample of XML Version
of State Department Telegram 42 Figure 5: The Long Now Foundation Rosetta
Disk Language

Archive 51 Figure 6: Internet Archive Collection of Presidential Candidate
Web Sites 54

Figure 7: Google?s Usenet Archive 55

Abbreviations

ASCII American Standard Code for Information Interchange DARPA Defense
Advanced Research Projects Agency DOD Department of Defense EAST Examiners
Automated Search Tool ERA Electronic Records Archive GAO General Accounting
Office GIS Geographic Information System GRS General Records Schedule GSA
General Services Administration HTML Hypertext Markup Language HUD Housing
and Urban Development IG Inspector General IT information technology NARA
National Archives and Records Administration NASA National Aeronautics and
Space Administration OAIS Open Archival Information System OMB Office of
Management and Budget PMO program management office POP persistent object
preservation PTO U. S. Patent and Trademark Office SAS State Archiving
System SF standard form VERS Victorian Electronic Record Strategy WEST Web
Examiner Search Tool XML Extensible Markup Language

Lett er

June 17, 2002 The Honorable Stephen Horn Chairman, Subcommittee on
Government Efficiency,

Financial Management and Intergovernmental Relations Committee on Government
Reform House of Representatives

The Honorable Ernest J. Istook, Jr. Chairman, Subcommittee on Treasury,
Postal Service and General Government

Committee on Appropriations House of Representatives

Agencies are increasingly moving to an operational environment in which
electronic- rather than paper- records provide comprehensive documentation
of their activities and business processes. Although this transformation has
improved the way federal agencies work and interact with each other and with
the public, it has also created the new challenge of managing and preserving
vast and rapidly growing volumes of electronic records. Because these
records document essential government functions and provide information
necessary to protect government and citizen

interests, their proper management is essential for ongoing government
activities; further, the preservation of significant documents and other
records is crucial for the historical record. Overall responsibility for the
government?s electronic records lies with the National Archives and Records
Administration (NARA), which carries out a dual mission for the nation:
oversight of records management, which governs the life cycle of records
(creation, maintenance and use, and disposition), and archiving, which is
the permanent preservation of documents and other records of historical
interest. In carrying out these

missions, NARA and agencies use a process known as scheduling to assess the
value of records and determine their disposition. The challenges associated
with managing and preserving electronic records have long been recognized
throughout government. Because of concern about these issues, you requested
that we review electronic records management and preservation activities at
NARA. Our objectives were to

 determine the status of NARA?s efforts to respond to governmentwide
electronic records management problems and the adequacy of its planned
actions and

 assess NARA?s efforts to acquire an archival system for electronic
records.

As part of our assessment of NARA?s efforts to acquire an electronic records
archiving system, you also asked that we identify alternative technologies
under consideration for the long- term preservation of electronic records.

To address our objectives, we reviewed applicable guidance and other
documentation; surveyed NARA?s appraisal archivists working with federal
agencies; reviewed records management activities and obtained the views

of record managers in selected federal agencies managing large volumes of
electronic records; and reviewed legal challenges to federal electronic
recordkeeping practices. We reviewed agency and contractors? documentation
for the electronic records archive program and assessed

NARA?s effort to develop or enhance its information technology capabilities.
Further details on our objectives, scope, and methodology are provided in
appendix I. Results in Brief NARA has taken action to respond to the
challenges associated with

managing and preserving electronic records. In 2001, NARA completed an
assessment of the current federal recordkeeping environment; this study
concluded that although agencies are creating and maintaining records
appropriately, most electronic records (including databases of major federal
information systems) remain unscheduled, and records of historical value are
not being identified and provided to NARA for preservation in

archives. As a result, valuable electronic records may be at risk of loss.
Part of the problem is that records management guidance is inadequate in the
current technological environment of decentralized systems producing large
volumes of complex records. Another factor is the low priority often given
to records management programs and the lack of technology tools to manage
electronic records. Finally, NARA does not perform systematic inspections of
agency records and records management programs, and so it does not have
comprehensive information allowing it to identify records management
implementation issues and areas where its guidance needs to be strengthened.
NARA plans to improve its guidance and to address

technology issues. However, NARA?s plans do not address the low priority

generally given to records management programs nor the issue of systematic
inspections. Recognizing the limitations of its technical strategies to
support preservation, management, and sustained access to electronic
records, NARA is planning to design, acquire, and manage an advanced
electronic records archive (ERA); however, this project faces substantial
risks. NARA is behind schedule for the ERA system, largely because of flaws
in how the schedule was developed. Further, to acquire a major system like
ERA, NARA needs to improve its information technology (IT) management
capabilities, and although it has made progress in doing so, its efforts are

not yet complete. Regarding alternative archiving technologies for
electronic records, we found that archival organizations now rely on a
mixture of evolving approaches that generally fall short of solving the
long- term preservation problem. Appendix II provides a detailed discussion
of these approaches.

In light of the continuing challenge of managing federal records, both
electronic and otherwise, we are recommending that the Archivist of the
United States develop a strategy for raising awareness of the importance of
federal records management programs and for performing systematic
inspections. In addition, to mitigate the risks associated with developing

the new archival system, we are recommending that the Archivist reassess the
schedule for this effort. In commenting on a draft of this report, the
Archivist stated that more must be done to address the enormous challenges
in managing and preserving electronic records and agreed with the report?s
recommendations. He also offered clarifications concerning records
management priority, inspections, and the ERA schedule that we have
incorporated as appropriate.

Background Advances in information technology and the explosion in computer
interconnectivity brought about by the Internet are irreversibly changing
the way we communicate and conduct business. Office automation applications
and networked desktop computers are providing the capability to rapidly
create and share electronic documents, use Web sites

for executing business and financial transactions, and instantaneously
communicate with individuals and groups. While the transformation from a
paper- based to an electronic business environment has led to

improvements in the way federal agencies do business, both with each other
and with the public, it has also created the new challenge of managing and
preserving electronic records, which must be approached differently from
their paper counterparts. Unlike paper records, electronic records are not
tangible, come in many formats, and depend on the hardware and software with
which they were created.

NARA?s mission is to ensure ?ready access to essential evidence? for the
public, the President, the Congress, and the Courts. NARA?s responsibilities
stem from the Federal Records Act, 1 which requires each federal agency to
make and preserve records that (1) document the organization, functions,

policies, decisions, procedures, and essential transactions of the agency
and (2) provide the information necessary to protect the legal and financial
rights of the government and of persons directly affected by the agency?s

activities. Effective management of these records is critical for ensuring
that sufficient documentation is created; that agencies can efficiently
locate and retrieve records needed in the daily performance of their
missions; and that records of historical significance are identified,

preserved, and made available to the public. According to NARA, without
effective records management, the records needed to document citizens?
rights, actions for which federal officials are responsible, and the
historical experience of the nation will be at risk of loss, deterioration,
or

destruction. Under the act, NARA is responsible for oversight of records
management and archiving. Records management- that is, the policies,
procedures, guidance, tools and techniques, resources, and training needed
to design and maintain reliable and trustworthy records systems- governs the
life cycle of records from creation, through maintenance and use, to final
disposition. Archiving is the permanent preservation of records documenting
the activities of the government. NARA thus oversees agency management of
temporary records used in everyday operations and

ultimately takes control of permanent agency records judged to be of
historic value. 2 Of the total number of federal records, less than 3
percent are designated permanent. 1 44 U. S. C. chapters 21, 29, 31, and 33.
2 NARA?s regulations implementing the Federal Records Act are found at 36
CFR 1200- 1280.

NARA Is Responsible for NARA is responsible for issuing records management
guidance; working Oversight of Records

with agencies to implement effective controls over the creation, Management

maintenance, and use of records in the conduct of agency business; providing
oversight of agencies? records management programs; and providing storage
facilities for certain temporary agency records. The Federal Records Act
also authorizes NARA to conduct inspections of agency records and records
management programs.

NARA works with agencies to identify and inventory records, appraise their
value, and determine whether they are temporary or permanent, how long the
temporary records should be kept, and under what conditions both the
temporary and permanent records should be kept. This process is called
scheduling. No record may be destroyed unless it has been

scheduled, and for temporary records the schedule is of critical importance
because it provides the authority to dispose of the record after a specified
time period. Records are governed by schedules that are specific to an
agency or by a general records schedule, which covers records common to
several or all agencies. According to NARA, records covered by general
records schedules make up about a third of all federal records. For the
other two thirds, NARA and the agencies must agree upon specific records
schedules. Once a schedule has been approved, the agency must issue it as

a management directive, train employees in its use, apply its provisions to
temporary and permanent records, and evaluate the results.

While the Federal Records Act covers documentary material regardless of
physical form or media, records management and archiving were until recently
largely focused on handling paper documents. With the advent of

computers, both records management and archiving have had to take into
account the creation of records in varieties of electronic formats. NARA?s
basic guidance for the management of electronic records is in the form of a
regulation at 36 CFR Part 1234. This guidance is supplemented by the
issuance of periodic NARA bulletins and a records management handbook,

Disposition of Federal Records. NARA?s guidance has two basic requirements.
First, agencies are required to maintain an inventory of all agency
information systems. The inventory should identify (1) the system?s name;
(2) its purpose; (3) the agency programs supported by the system; (4) data
inputs, sources, and outputs; (5) the information content of databases; and
(6) the system?s hardware and software environment. Second, NARA requires
agencies to schedule the electronic records maintained in its systems.
Agencies must either schedule those records under specific schedules,
completed through submission and approval of

Standard Form 115 (SF 115), Request for Records Disposition Authority,

or pursuant to a general records schedule. NARA relies on this combination
of inventory and scheduling requirements to ensure the management of agency
electronic records consistent with the Federal Records Act.

NARA has also established a general records schedule for electronic records.
General Records Schedule 20 (GRS 20) authorizes the disposal of certain
categories of temporary electronic records. It has been revised

several times over the years in response to developments in information
technology, as well as legal challenges. (App. III provides a discussion of
the evolution of electronic records guidance and legal challenges to GRS
20.)

As it stands now, GRS 20 applies to electronic records created both in
computer centers engaged in large- scale data processing and in the office
automation environment. With regard to computer centers, GRS 20 authorizes
the disposal of certain types of scheduled electronic records associated
with large database systems, such as inputs, outputs, and

processing files. With regard to the office desktop environment, GRS 20
authorizes the deletion of the electronic version of records on word
processing and electronic mail systems once a recordkeeping copy has been
made. In addition, it authorizes deletion of electronically generated
administrative spreadsheets and other administrative records that are
included in recordkeeping systems that have been authorized for disposal by
NARA. Since most agency ?recordkeeping systems? are paper files, GRS 20
essentially authorizes agencies to destroy E- mail and word- processing
files once they are printed. As already noted, records not covered by a
general records schedule may not be destroyed unless authorized by a records
schedule that has been approved by NARA.

GRS 20 does not address many common products of electronic information
processing, particularly those that result from the now prevalent
distributed, end- user computing environment. For example, although the

guidance addresses the disposition of certain types of electronic records
associated with large databases, it does not specifically address the
disposition of electronic databases created by microcomputer users. In
addition, while addressing word processing and E- mail records, GRS 20

does not address more recent forms of electronic records such as Web pages
and portable document format (PDF) files. 3 NARA Archives Permanent

As the nation?s archivist, NARA accepts for deposit to its archives those
Records of Historical records of federal agencies, the Congress, the
Architect of the Capitol, and Interest

the Supreme Court that are determined to have sufficient historical or other
value to warrant their continued preservation by the U. S. government. NARA
also accepts papers and other historical materials of the Presidents of the
United States, documents from private sources that are appropriate for
preservation (including electronic records, motion

picture films, still pictures, and sound recordings), and records from
agencies whose existence has been terminated, including Offices of
Independent Counsel (see fig. 1).

Figure 1: Removable Hard Drives and Backup Devices Used by Independent
Counsel Staff

Source: NARA.

3 PDF is a proprietary format of Adobe Systems, Inc., that preserves the
fonts, formatting, graphics, and color of any source document, regardless of
the application and platform used to create it.

NARA archives vast quantities of federal records in various formats. Its
archival facilities (a network of regional archives) hold over 21 million
cubic feet of original textual materials, while its multimedia collections
include nearly 300, 000 reels of motion picture film; more than 5 million
maps, charts, and architectural drawings; over 200,000 sound and video
recordings; about 9 million aerial photographs; nearly 14 million still
pictures and posters; and over 87,000 computer data sets stored on

computer tapes and cartridges (see fig. 2).

Figure 2: Master Copies of Electronic Records in NARA?s Archives

Source: NARA.

In addition to its archives, NARA also manages the archival holdings of 10
presidential libraries, the Nixon presidential materials staff, and the
Clinton presidential materials project. These include over 400 million paper
records, over 15 million feet of film, nearly 10 million still pictures,
nearly 100,000 hours of audio and video recordings, and almost half a
million museum objects.

The types of electronic records that NARA currently accepts for archiving
are limited to those that are independent of specified hardware or software
and are in text- based formats, such as databases and certain text- based
geographic information system (GIS) 4 files. NARA does not accept digital
images, Web pages, word processor files, relational databases, or any
records with complex structure. 5 (Although NARA does not as yet accept such
files for archiving, they must still be scheduled.) Management and

During the last four decades, archiving- the permanent preservation of
Preservation of Electronic information of enduring value for access by
future generations- has

Records Pose Major undergone a major change. Before the advent of large
bureaucracies Challenges

supported by the now ubiquitous computer, archivists dealt with a scarcity
of sources, with much of their efforts focused on tracking down unique
manuscripts or recovering incomplete files. 6 The archived records were
relatively durable- clay tablets, stone, parchment, vellum, or rag paper.
Albeit scarce and often incomplete, these records come down through the

centuries relatively intact and could be preserved with little or no
difficulty. The growth of the government, complex organizations, and advent
of the electronic age have reversed the conditions facing today?s archives:
rather than dealing with scarce sources, the archives are facing a flood of
potentially valuable information stored on fragile materials, including pulp

paper and computer tapes and disks. While the preservation of information
recorded on traditional materials such as paper or film requires significant
resources, the current major archival challenge is the preservation of
electronic records. Like traditional archival materials- books, papers, or
film- electronic information is recorded on media that deteriorate with age.
However, unlike the

traditional archival materials, electronic records are stored in specific 4
A geographic information system is a computer system for capturing, storing,
checking, integrating, manipulating, analyzing, and displaying data related
to positions on the Earth?s surface. Typically, a GIS is used for handling
maps of one kind or another. These might be represented as several different
layers where each layer holds data about a particular kind of feature (e.
g., roads). Each feature is linked to a position on the graphical image of a
map.

5 In January 2001, NARA directed agencies to provide a one- time ?snapshot?
of their public Web sites as they existed on or before January 20, 2001. 6
National Research Council, Preservation of Historical Records, National
Academy Press (Washington, D. C.: 1986).

formats and cannot be read without software and hardware- sometimes the
specific types of hardware and software on which they were created.

The rapid evolution of information technology makes the task of managing and
preserving electronic records complex and costly. Agencies are increasingly
moving to an operational environment in which electronic- rather than paper-
records provide comprehensive documentation of their activities and business
processes. Part of the challenge of managing electronic records is that they
are produced by a mix of information systems, which vary not only by type
but by generation of technology: the mainframe, the personal computer, and
the Internet. Each generation of technology brought in new systems and
capabilities without displacing the

older systems. 7 Thus, organizations have to manage and preserve electronic
records associated with a wide range of systems, technologies, and formats.
The challenge of managing and preserving vast and rapidly growing volumes of
electronic records produced by modern organizations is placing pressure on
the archival community and on the information industry to develop a cost-
effective long- term preservation strategy that would free electronic
records of the straitjacket of proprietary file formats and software and
hardware dependencies. This challenge is affected by several

factors: decentralization of the computing environment, the complexity of
electronic records, obsolescence and aging of storage media, massive volumes
of electronic records, and software and hardware dependencies.

 Decentralization of computing environment: The challenge of managing
electronic records significantly increases with the decentralization of the
computing environment. In the centralized environment of a mainframe
computer, it is relatively easy to identify, assess, and manage electronic
records. This is not the case in the decentralized environment of agencies?
office automation systems, where every user is creating electronic files
that may constitute a formal record and thus should be preserved.

 Complexity of electronic records: Electronic records have evolved from
simple text- based files to complex digital objects that may contain
embedded images (still and moving), drawings, sounds, hyperlinks, or

7 International Council on Archives, Guide for Managing Electronic Records
from an Archival Perspective (Paris: February 1997).

spreadsheets with computational formulas. Some portions of electronic
records, such as the content of dynamic Web pages, are created on the fly
from databases and exist only during the viewing session. Others, such as E-
mail, may contain multiple attachments, and they may be threaded (that is,
related E- mail messages are linked into send- reply chains). These records
cannot be converted to paper or text formats without the loss of context,
functionality, and information.  Obsolescence and aging of storage media:
Storage media are affected

by the dual problems of obsolescence and decay. They are fragile, have
limited shelf life, and become obsolete in a few years. Few computers today
have disk drives that can read information stored on 8- or 5ï¿½- inch
diskettes, even if the diskettes themselves remain readable.

 Massive volumes: Electronic records are increasingly being created in
volumes that pose significant technical challenge to our ability to organize
and make them accessible. For example, among the candidates

for archiving are military intelligence records comprising more than 1
billion electronic messages, reports, cables, and memorandums, as well as
over 50 million electronic court case files.

 Software and hardware dependency: Electronic records are created on
computers with software ranging from word- processors to E- mail programs.
As computer hardware and application software become

obsolete, they may leave behind electronic records that cannot be read
without the original hardware and software.

Past GAO Work Highlighted In July 1999, we reported that NARA and federal
agencies were facing the Electronic Records Challenges

substantial challenge of preserving electronic records in an era of rapidly
changing technology. 8 In that report we stated that in addition to handling
the burgeoning volume of electronic records, NARA and the agencies would
have to address several hardware and software issues to ensure that
electronic records were properly created, maintained, secured, and

retrievable in the future. We also noted that NARA did not have
governmentwide data on the records management capabilities and programs of
all federal agencies. As a result, we recommended that NARA conduct a
governmentwide survey of agencies? electronic records 8 U. S. General
Accounting Office, National Archives: Preserving Electronic Records in an
Era of Rapidly Changing Technology, GGD- 99- 94 (Washington, D. C.: July 19,
1999)

(http:// www. gao. gov/ archive/ 1999/ gg99094. pdf).

management programs and use the information as input to its efforts to
reengineer its business processes. NARA?s subsequent efforts to assess
governmentwide records management practices and study the redesign of its
business processes are discussed later in this report. Agencies Are
Beginning to In response to the difficulty of manually managing electronic
records, Automate Management of

agencies are slowly turning to automated records management Electronic
Records applications to help automate electronic records management life-
cycle processes. The primary functions of these applications include
categorizing

and locating records and identifying records that are due for disposition,
as well as storing, retrieving, and disposing of electronic records that are
maintained in repositories. Also, some applications are beginning to be
designed to automatically classify electronic records and assign them to an
appropriate records retention and disposition category.

The Department of Defense (DOD), which is pioneering the assessment and use
of records management applications, has published application standards and
established a certification program. 9 The DOD standard, endorsed by NARA,
includes the requirement that records management applications acquired by
DOD components after 1999 be certified to meet this standard. 10 As of March
2002, DOD had certified 31 applications. NARA

was testing one of the DOD- certified electronic records management
applications, and it will be assessing the second version of the DOD
standard to determine whether it can or should become a governmentwide
standard.

Theory, Methods, and Model for NARA is not alone in facing the challenges
posed by electronic records,

Long- Term Preservation of particularly long- term preservation. There is a
general consensus in the

Electronic Records Are Being archival community that a viable strategy for
the long- term preservation

Developed and archiving of electronic records has yet to be developed.
Accordingly, archives scholars, national archival and library institutions,
and private

industry representatives are collaborating on major initiatives to develop
the theoretical and methodological knowledge needed for the permanent 9
Department of Defense, Design Criteria Standard for Electronic Records
Management Software Applications, DOD 5015. 2- STD (November 1997)

(http:// www. dtic. mil/ whs/ directives/ corres/ html/ 50152std. htm).

10 DOD 5015.2- STD requires that records management applications be able to
manage records regardless of their media.

preservation of records created in electronic systems. These initiatives
include the following:

 The International Research on Permanent Authentic Records in Electronic
Systems project is a major two- phase international research project in
which archival and computer engineering scholars, national archival
institutions (including NARA), and private industry representatives are
collaborating to develop the theoretical and methodological knowledge
required for the permanent preservation of authentic records created in
electronic systems. The first phase of the

project, focusing on records generated in databases and document management
systems, was recently completed; the second phase (2002 to 2006) deals with
the issues of authenticity, reliability, and accuracy of records produced in
new digital environments.

 The Library of Congress? National Digital Information Infrastructure and
Preservation Program is a national cooperative effort led by the Library to
develop the strategy and technical approaches needed to archive and preserve
digital information; NARA is also participating in this effort. The program
is in an early stage; completion is not expected until 2004 or 2005, when
the Library will provide recommendations to the Congress.

 NARA is collaborating in a joint effort on electronic record archiving
with the Defense Advanced Research Projects Agency (DARPA), the U. S. Patent
and Trademark Office, the National Partnership for Advanced Computational
Infrastructure, and the San Diego

Supercomputer Center. Led by DARPA, the collaboration aims to develop and
demonstrate architectures and technologies for electronic archiving and the
development of persistent object preservation, a proposed technique for
electronic archiving (discussed in app. II). These initiatives are all in
their early stages; none of them has yet yielded

proof- of- concept prototypes demonstrating the viability of a long- term
solution to preserving and accessing electronic records. Progress has been
made, however, in the development of a standard model for electronic
archiving systems. The Open Archival Information System (OAIS) model, which
is currently emerging as a standard in the archival community, was initially
developed by the National Aeronautics and Space Administration (NASA) for
archiving the large volumes of data produced by space missions. However, the
model is applicable to any archive, digital

library, or repository. As a standard framework for long- term preservation
archives, the model defines the environment necessary to support a digital
repository and the interactions within that environment. According to NASA,
it also promotes the understanding and increased awareness of archival
concepts needed for long- term digital information preservation

and access, as well as for describing and comparing architectures and
operations of existing and future archives.

Many institutions have already chosen to use the framework of the OAIS
reference model to guide their digital preservation efforts, including the
National Library of the Netherlands, NARA (in conjunction with the
development of its electronic records archiving project), NASA?s National
Space Science Data Center, and many commercial organizations. The OAIS model
(see fig. 3) breaks the archiving system down into six distinct functional
areas: ingest, archival storage, data management, administration,
preservation planning, and access.

 In the ingest area, systems accept information submitted from outside the
framework and prepare the contents for storage. This functional area also
includes systems to generate descriptive information to allow future
management within the archive.

 In the archival storage area, systems pass the information, now called
archival information packages, into a storage repository, where it is
maintained until the contents are requested and retrieved.

 The data management area encompasses the services and functions for
populating, maintaining, and accessing both descriptive information that
identifies and documents archive holdings and administrative data used to
manage the archive.  The administration area provides the services and
functions for the overall operation of the archive system.

 In the preservation planning area, systems monitor the environment of the
OAIS and provide recommendations to ensure that the information stored in
the OAIS remains accessible, even if the original computing environment
becomes obsolete.

 The access area includes systems that allow a user to determine the
existence, description, location, and availability of information stored in
the OAIS, allowing information products to be requested and received.

Figure 3: OAIS Model and Its Components

Source: Consultative Committee for Space Data Systems.

The OAIS framework does not presume or apply any particular preservation
strategy. This approach allows organizations that adopt the framework to
apply their own strategies or combinations of strategies. The framework does
assume that the information managed is produced outside the OAIS, and that
the information will be disseminated to users who are

also outside the system. Because the model is simplified to include only
functions common to all repositories, it allows institutions to focus on the
approaches necessary to preserve the information.

NARA Is Responding to NARA is taking action to respond to long- standing
problems associated Challenges of

with managing and preserving electronic records in archives. In 2001, NARA
completed an assessment of governmentwide records management Electronic
Records

practices. This assessment concluded that although agencies are creating
Management sufficient records and maintaining them appropriately, most
electronic records remain unscheduled, and permanent records of historical
value are

not being identified and provided to NARA for preservation and archiving. As
a result, potentially valuable records may be at risk.

According to the study, the problems in electronic records management appear
to stem from (1) inadequate governmentwide records management guidance and
(2) the low priority traditionally given to federal records management
functions and a lack of technology tools to manage electronic records. To
address these problems, NARA now plans to (1) analyze key policy issues
related to the disposition of records and improve its guidance and (2)
examine and redesign, if necessary, the scheduling and appraisal

process and make this process more effective through the use of technology.
NARA?s plans, however, do not address the low priority given to records
functions. Further, these plans do not address the need to monitor
performance of records management programs and practices on an

ongoing basis. NARA?s Assessment of

Records must be effectively managed throughout their life cycle, which
Federal Records Practices

includes records creation, maintenance and use, and scheduling and
Identifies Problems

disposition. Agencies must create reliable records that meet the business
needs and legal responsibilities of federal programs and (to the extent
known) the needs of internal and external stakeholders who may make
secondary use of the records. To maintain and use the records created,
agencies are to create internal recordkeeping requirements for maintaining
records, consistently apply these requirements, and establish systems that
allow them to find records that they need. Scheduling is the means by

which NARA and agencies identify federal records, determine time frames for
disposition, and identify permanent records of historical value that are to
be transferred to NARA for preservation and archiving. With regard
particularly to electronic records, agencies are also to compile inventories
of their information systems, after which the agency is required to develop
a schedule for the electronic records maintained in those systems.

In 2001, NARA completed an assessment of governmentwide records management
practices, as recommended in our prior work. The assessment included a
recordkeeping study performed by a contractor- SRA International- and a
series of records system analyses performed by NARA staff. The SRA study was
based on a survey of federal employees representing over 150 federal
government organizations and on 54 focus

groups and interviews involving individuals from 18 agencies; the NARA
staff?s records system analyses focused on records management practices for
key business processes in 11 federal agencies.

The resulting NARA/ SRA study identified problems in agency records
management. 11 Specifically, NARA?s assessment of records management for key
processes in 11 agencies concluded the following.

 Records creation: In general, the NARA study showed that the processes
that were studied appeared to generate adequate records documentation.

 Records maintenance and use: For the most part, recordkeeping requirements
were adequate, documented, and consistently applied. In addition, employees
were generally able to find the records that they

needed.

 Records scheduling and disposition: The study identified significant
problems in both records scheduling and disposition. According to the study,
many significant records- as well as most federal electronic records- are
unscheduled. In addition to the unscheduled records, NARA identified several
significant records that had been improperly scheduled. The study concluded
that records scheduling was clearly a

problem area. Our review at four agencies (Commerce, Housing and Urban
Development, Veterans Affairs, and State) provides confirmation of this
result, eliciting a collective estimate that less than 10 percent of
mission- critical systems were inventoried. The number of mission- critical
systems at these four agencies was reported to be 907, according to
information collected by the Office of Management and Budget in November
1999 as part of the federal government?s effort to assess the Year 2000
computing challenge. 12 Thus for these four agencies alone, over 800 systems
had not been inventoried and

the electronic records maintained in them had not been scheduled. Scheduling
the electronic records in a large number of major information systems
presents an enormous challenge, particularly since it generally

11 SRA International, Inc., Report on Current Recordkeeping Practices within
the Federal Government (Dec. 10, 2001) (http:// www. nara. gov/ records/
rkreport. html). Both the SRA study and the NARA staff analyses were
reported within this document. 12 The 24 major agencies reported 6, 435
mission- critical systems. Subcommittee on Government Management,
Information, and Technology, House Committee on Government Reform, Federal
Government Earns B+ on a Final Y2K Report Card, news release

(Washington, D. C.: Nov. 22, 1999).

takes NARA, in conjunction with agencies, well over 6 months to approve a
new schedule. 13 Failure to inventory systems and schedule records places
these records at risk. The absence of inventories and schedules means that
NARA and agencies have not examined the contents of these information
systems to identify official government records, appraised the value of
these records, determined appropriate disposition, and directed and trained
employees in how to maintain and when and how to dispose of these records.
As a result,

temporary records may remain on hard drives and other media long after they
are needed or could be moved to less costly forms of storage. In addition,
there is increased risk that these records may be deleted prematurely while
still needed for fiscal, legal, and administrative purposes. The lack of
scheduling presents particular risks to the preservation of permanent
records of historic significance. NARA?s study of 11 agencies found
instances where valuable permanent electronic records were not being
appropriately transferred to NARA?s archives because these records had not
been scheduled, appraised, identified as permanent, and placed

under the control of the agency?s records program. This lack of management
control places these valuable records at increased risk of loss,
destruction, and deterioration.

NARA?s Records Management The NARA/ SRA study identified the lack of
sufficient governmentwide Guidance Has Not Kept Pace

guidance as one cause of records management problems. As NARA has with the
Challenges of Electronic

acknowledged, its policies and processes on electronic records have not
Records

yet evolved to reflect the modern recordkeeping environment: records created
electronically in decentralized processes. 14 Despite repeated attempts to
clarify its electronic records guidance through a succession of NARA
bulletins, the current guidance remains incomplete and confusing.

According to the study, for example, employees lack knowledge concerning how
to identify electronic records and what to do with them once identified. The
guidance does not provide disposition instructions for 13 According to NARA,
its current goals for schedule processing are 180 days for simple schedules
and 365 days for complex schedules. In FY 2001 the median time for
completing schedules was 237 days.

14 National Archives and Records Administration, An Overview of Three
Projects Relating to the Changing Federal Recordkeeping Environment (January
2001) (http:// www. nara. gov/ records/ rmioverview. html).

electronic records maintained in many of the common types of formats
produced by federal agencies, including PDF files, Web pages, and
spreadsheets. To support their missions, many agencies must maintain such
records- often in large volumes- with little guidance from NARA (see app. IV
for a discussion of the records management challenges faced by selected
agencies). The NARA/ SRA study concluded that while agencies appreciate the
specific assistance from NARA personnel, they are frustrated because they
perceive that NARA is not meeting agencies? broader needs for guidance and
records management leadership. This study reported that agencies

believe that NARA has a responsibility to lead the way in transitioning to
an electronic records environment and to provide guidance and standards, as
well as tools to enable agencies to follow the guidance. According to the

study, some viewed NARA as leaving agencies to fend for themselves,
sometimes levying impossible requirements that pressure agencies to come up
with their own individual solutions.

Agency Records Management The NARA/ SRA study identified another cause of
records management Programs Are Given Low Priority difficulties: the low
priority generally afforded to records management and Lack Technology Tools

programs. The study states that records management is not even ?on the radar
scope? of agency leaders. Further, records officers have little clout and do
not appear to have much involvement in or influence on

programmatic business processes or the development of information systems
designed to support them. New government employees seldom receive any
formal, initial records management training. One agency told NARA that
records management is ?number 26 on our list of top 25 priorities.? The
study also noted that federal downsizing may have negatively affected
records management and staffing resources in agencies.

Further, records management is generally considered a ?support? activity.
Since support functions are typically the most dispensable in agencies,
resources for and focus on these functions are often limited. This finding
was echoed by a recent review of archival practices of research
universities, corporate research and development programs, and federal

science agencies, which noted that ?agency records management programs

lack the resources to meet even the legally required standards of securing
adequate documentation of their programs and activities.? 15

As indicated by the NARA/ SRA study, a related issue is the technical
challenge of electronic records management: effective electronic records
management may require more sophisticated and expensive information
technology (such as automated electronic records management systems) than
was previously necessary for paper- based records management programs.
Because management tends not to focus on records

management, priority has not been given to acquiring or upgrading the
technology required to manage records in an electronic environment. The
study noted that technology tools for managing electronic records do not
exist in most agencies, and further, that agency information technology

environments have not been designed to facilitate the retention and
retrieval of electronic records. As a result, despite the growth of
electronic media, agency records systems are predominantly in paper format
rather than electronic.

The study further noted that agencies planning or piloting automated
electronic records management systems perform better recordkeeping than
those without such tools. Typically, such agencies are already performing
better recordkeeping, and they tend to invest in electronic records
management systems because of the value they place on good records
management. According to the study, many agencies are either planning or
piloting information technology initiatives to support electronic records
management, but their movement to electronic systems

is constrained by the level of financial support provided for records
management. Inspections of Federal

A possible further cause of agency records management problems, not
Electronic Records Programs addressed in the NARA/ SRA study, is the limited
nature of NARA?s current Are Limited

inspection program. NARA is responsible, under the Federal Records Act, for
conducting inspections or surveys of agency records and records management
programs and practices. Its implementing regulations require

NARA to select agencies to be inspected (1) on the basis of perceived need
by NARA, (2) by specific request by the agency, or (3) on the basis of a

15 Center for History of Physics, American Institute of Physics, AIP Study
of Multiinstitutional Collaborations: Final Report- Highlights and Project
Recommendations,

College Park, MD (2001) (http:// www. aip. org/ history/ pubs/ collabs/
highlights. html).

compliance monitoring cycle developed by NARA. 16 In all instances, NARA is
to determine the scope of the inspection. Such inspections provide not only
the means to assess and improve individual agency records management
programs but also the opportunity for NARA to determine overall progress in
improving agency records management and identify problem areas that need to
be addressed in its guidance.

Between 1996 and 2000, NARA performed 16 inspections of agency records
management programs, or about 3 per year. These reviews were systematic and
comprehensive, covering all aspects of an agency?s records program. However,
only 2 of the 24 major executive departments or agencies were evaluated,
with most of NARA?s evaluations focused on component organizations or
independent agencies. Moreover, these evaluations frequently bypassed the
issue of electronic records.

In 2000, NARA replaced agency evaluations with a new inspection approach-
targeted assistance. NARA decided that its previous approach to inspections
was basically flawed: besides reaching only a few agencies, it was often
perceived negatively by agencies and resulted in a list of

records management problems that agencies then had to resolve on their own.
Under the targeted assistance approach, NARA enters into partnerships with
federal agencies to provide them with guidance, assistance, or training in
any area of records management. Services offered include expedited review of
critical schedules, tailored training, and help in records disposition and
transfer.

However, although this approach may improve records management in the
targeted agencies, it is not a substitute for systematic inspections and
evaluations of federal records programs. Because the targeted assistance
program is voluntary and, according to NARA, initiated by a written request
from the agency, relying on it exclusively could significantly limit NARA?s
evaluations of federal recordkeeping. First, only agencies requesting
targeted assistance- presumably those already having greater appreciation

of the importance of records management- are evaluated. Second, the scope
and the focus of the targeted assistance are not determined by NARA but by
the requesting agency.

16 CFR 1220. 54 (a).

NARA Is Addressing NARA has recognized that its policy and regulations for
the management

Records Management and disposition of electronic records must be revised to
provide agencies Problems, but Additional with clear and comprehensive
guidance encompassing all types and Opportunities Exist formats of
electronic records. Having completed its assessment of federal records
management practices, NARA now plan a two- phase project to (1) analyze key
policy issues related to the disposition of records and

improve governmentwide guidance, and (2) examine and redesign, if necessary,
the scheduling and appraisal process and make this process more effective
through the use of technology. According to NARA, the purpose of the first
phase of the project is to analyze and make decisions, as necessary, on key
policy issues related to determining the disposition of records. NARA plans
to evaluate current

legislation, regulations, and guidance to determine if these are adequate in
the current recordkeeping environment. NARA expects the outcome of the first
phase, scheduled for completion by the end of fiscal year 2002, to be policy
decisions that support the appropriate disposition of all government
documentation in today?s multimedia environment. 17 These results are also

intended, as recommended in our prior work, to inform the redesign of the
current scheduling and appraisal process planned for the second phase of the
project, the development of electronic recordkeeping requirements, and
improvements to records management guidance and assistance to agencies. In
the second phase, NARA plans to examine and redesign, if necessary, the
process used by the federal government to determine the disposition of
records. This is planned as a multiyear process (2003 to 2006) during which
NARA intends to address the scheduling and appraisal of federal records in
all formats. Currently, it takes NARA well over 6 months to approve a new

schedule. According to NARA, the extensive appraisal time delays action on
the disposition of records and discourages agencies from submitting
schedules, potentially putting essential evidence at risk. NARA has two

goals for this project: (1) making the process for determining the
disposition of records, regardless of medium, more effective and efficient
and dramatically decreasing the amount of time it takes to get approval for

the disposition of records from the Archivist of the United States, and (2)
deciding how to appropriately apply technology to support the revised 17
NARA expects the policy review phase to be completed by the end of 2002, but
according to NARA, all new or revised policies will not be in place by that
date. The entire project will not be complete until 2006.

process for determining the disposition of records as part of managing
records throughout their life cycle.

Although NARA?s plans address the need to improve guidance and determine how
to use technology to support records management, these plans do not address
another issue raised in its study: the low priority generally given to
records management and the related lack of management commitment and
attention to these functions. Without a strategy to establish senior- level
agency commitment to records

management and raise awareness of its importance to the federal government,
these programs are likely to continue to be regarded by agency management
and employees as low- priority ?support? functions.

In addition, NARA?s plans do not address the issue of systematic
inspections. While the results of its recent study provide a baseline of
governmentwide records management practices, NARA?s targeted assistance
approach does not provide systematic and comprehensive information to assess
progress over time. Without this type of data, NARA will be impaired in its
ability to determine if it is achieving results in improving agency records
management. Further, NARA may not have the means to identify agency
implementation issues and areas where its

guidance needs to be clarified, augmented, and strengthened. The feedback
provided by inspection is especially critical now as NARA plans to redesign
the scheduling and appraisal process, and improve its guidance.

NARA?s Effort to Archiving- the final phase of records management for
permanent Acquire Advanced records- presents a significant challenge when
records are electronic. In light of the growth in the volume, complexity,
and diversity of electronic Electronic Archival

records, NARA has recognized that its technical strategies to support System
Faces Risks

preservation, management, and sustained access to electronic records are
inadequate and inefficient. To address this challenge, the agency is
pursuing two strategies. Its short- term strategy is to extend the useful
life of its current systems and to create some new systems for archiving
electronic records and for cataloging and displaying electronic records
online. NARA?s long- term strategy, on which it is placing its primary
focus, is to contract with a private sector firm to acquire (that is,
obtain) an advanced electronic records archive (ERA). However, NARA faces
substantial risks in implementing its long- term strategy. NARA is not
meeting its schedule for the ERA system, largely because of flaws in how the
schedule was developed. As a result, the

schedule will be compressed, increasing risks. Further, although NARA
recognizes that to be successful it must improve its information technology
(IT) management capabilities and has made progress in doing so, these
efforts are not yet complete.

NARA Is Planning to NARA?s long- term strategic initiative is to develop an
advanced electronic Acquire an Advanced

records archive. The agency?s goals for this system are to preserve and
Electronic Records provide access to any kind of electronic record, free
from dependency on Archiving System

any specific hardware or software, so that the agency can carry out its
mission into the future. Although the new archival system is not yet
formally defined, agency documents, public presentations, and interviews
with agency officials and staff indicate, in broad outline, how they
envision this system. It will probably be a distributed system, allowing the
storage and management of massive record collections at a variety of
installations, with accessibility provided via the Internet. It may be based
on persistent object preservation, an advanced form of file format
conversion and encapsulation (described in app. II) that is the subject of
research sponsored by NARA and other organizations. A leading candidate for
performing this encapsulation and capturing the necessary information is the
Extensible Markup Language (XML), which provides a means for ?tagging?
(annotating) information in a meaningful fashion that can be

readily interpreted by disparate computer systems (XML is further discussed
in app. II).

NARA has indicated that ERA will be a major system, and that it is likely
that it will be developed and implemented in several phases (or ?builds?),
with each phase adding more functions to the system. According to NARA, its
development will take several years, and it will involve a significant
expenditure of resources on program management, research, and systems
development activities.

NARA is planning to award the contract for the new electronic archival
system in January 2004. Table 1 is a timeline showing key tasks for the
program.

Table 1: Timeline for ERA Program Key ERA tasks Completion dates

Develop vision statement March 1, 2002 a Develop concept of operations April
1, 2002 b Conduct market survey June 28, 2002 Perform analysis of
alternatives July 22, 2002 Develop cost estimates August 19, 2002 Develop
high- level conceptual and functional

September 24, 2002 requirements Develop business case/ economic analysis
September 30, 2002

Develop final functional requirements December 2, 2002 Issue Request for
Information January 13, 2003 Release Request for Proposal August 4, 2003
Fiscal year 2004 budget for ERA In effect October 1, 2003 Award ERA contract
January 12, 2004 a Completed April 18, 2002. b Completed in draft on April
1, 2002.

To assist in this effort, NARA contracted with Integrated Computer
Engineering (ICE), Incorporated, 18 a private company experienced in systems
development and acquisition. With the assistance of this contractor, NARA
has been establishing the ERA program management office. Since July 2001,
the program management office has been focused

on developing the capability to manage the development and acquisition of
the ERA system. NARA is also funding two independent assessments of the
research into the technology that is proposed for ERA. These two independent
assessments, conducted by the National Academy of Sciences, will review
research that NARA is now sponsoring, as well as alternative approaches. The
first assessment is a technical review of the viability of persistent object

preservation, the architecture for persistent archives of electronic records
that is being researched by the National Partnership for Advanced
Computational Infrastructure (see app. II). This assessment- scheduled

18 On January 15, 2002, American Systems Corporation (ASC) announced its
acquisition of ICE, Inc. According to the ERA project manager, this change
does not affect the status of NARA?s contract with ICE, Inc.

for completion on January 31, 2003- will address the adequacy and soundness
of the persistent object preservation architecture as a whole, as well as
its major components, from the points of view of computer science, systems
engineering, and archival sciences. NARA has stated that the assessment of
the persistent object information management architecture and its technical
validation should be completed before ERA is developed.

In its fiscal year 2002 budget hearings, NARA referred to the articulation
of the persistent object preservation architecture as the one ?major

dependency? in its strategy for acquiring an ERA system. The second
assessment will identify and evaluate alternative methods for digital
preservation of records, examine the operational use of the Internet for
digital archiving, and identify those aspects of the preservation of
electronic records that cannot be adequately addressed either by state-
ofthe- art information technology or by technologies under development. It
will also address the feasibility of commercializing new ideas from

research. According to NARA, the second assessment is to be completed 6 to 9
months after the first. ERA Schedule Faces

Although the ERA project is still in its initial stages, it is already
falling Significant Risks

behind schedule. As shown in table 1, the initial deliverables for design
and acquisition are late: the vision statement, due March 1, was not
completed until April 18, and the concept of operations, 19 due April 1, was
delivered in draft form on that date and had not been finalized as of May
31. This

lateness can be attributed to flaws in how the schedule was developed. In
its tracking of ERA risks, NARA has acknowledged that the schedule for
completion of tasks was based on incomplete work projections, and that its

deadlines may not be achievable. Rather than constructing a plan based on
estimates of the amount of work and resources required to complete each
task, NARA constructed a ?success oriented? schedule that was planned around
ensuring that ERA was funded beginning in fiscal year 2004.

In addition, the ERA program management office is behind schedule on its
efforts to develop the plans and guidance to strengthen its capability for
managing the acquisition and deployment of ERA. In July 2001, with the help
of its systems development and acquisition contractor, the office began
focusing on developing these plans and procedures. We tracked 19 A concept
of operations is a document that describes characteristics of the system
from the user?s viewpoint.

planned and actual completion dates for 13 policy and planning documents
that the program management office needs in order to develop and acquire a
major system (according to NARA and its contractor). To date, however, only
7 of the 13 documents have been completed. 20 The 7 that have been delivered
were late by an average of over 2 months. The initially planned

delivery dates of the other 6 documents have passed; on average these are
late by almost 4 months. 21

Besides the approach taken to constructing the schedule, another
contribution to schedule slippage may be NARA?s slow start in hiring
fulltime government staff for the ERA program management office. For fiscal
year 2002, NARA was authorized 16 positions for the ERA program office.
However, as of April 2002, NARA had only 5 full- time staff on board.

NARA Is Strengthening IT Acquiring a major IT system such as the planned
electronic archival system Management Capabilities,

is a significant challenge for a relatively small organization like NARA,
but These Efforts Are whose IT management capabilities are relatively
limited. In its fiscal year

Incomplete 2002 budget hearings, NARA indicated that it must strengthen its
IT management capabilities and infrastructure to support the ERA program,
and NARA is currently taking steps to do so in three key areas: IT

investment management, enterprise architecture, and information security.
None of these efforts, however, is yet complete.

Sound IT Management IT investment management provides a systematic method
for agencies to Capabilities Contribute to minimize risks while maximizing
the return on investments. The ClingerCohen Success in Acquiring IT Systems

Act requires agency heads to implement a process for maximizing the value
and assessing and managing the risks of an agency?s IT investments. Our
research of leading private and public sector

organizations? IT management practices indicates that effective investment
management requires the use of defined and disciplined investment management
processes. 20 The seven completed documents were the acquisition strategy,
configuration management plan, risk management plan, quality assurance plan,
life- cycle model, requirements management plan, and technology research
plan. 21 The six uncompleted documents were the revised program management
office (PMO) organization, PMO billet roles/ responsibilities, metrics plan,
PMO training needs assessment, ERA PMO training plan, and program management
plan.

An enterprise architecture provides a description- in useful models,
diagrams, and narrative- of the mode of operation for an agency. It
describes the agency in both (1) logical terms, such as interrelated
business processes and business rules, information needs and flows, and work
locations and users; and (2) technical terms, such as hardware, software,
data, communications, and security attributes and standards. An enterprise
architecture provides these perspectives both for the current environment

and for the target environment, as well as a transition plan for sequencing
from the current to the target environment. Managed properly, an enterprise
architecture can clarify and help optimize the dependencies and

relationships among an agency?s business operations and the underlying IT
infrastructure and applications that support these operations.

Information security is an important consideration for any organization that
depends on information systems to carry out its mission. Our study of
security management best practices, as summarized in our 1998 executive
guide, 22 found that leading organizations manage their information security
risks through an ongoing cycle of risk management. This management

process involves (1) establishing a centralized management function to
coordinate the continuous cycle of activities while providing guidance and
oversight for the security of the organization as a whole, (2) identifying
and assessing risks to determine what security measures are needed, (3)
establishing and implementing policies and procedures that meet those needs,
(4) promoting security awareness so that users understand the risks and the
related policies and procedures in place to mitigate those risks, and

(5) instituting an ongoing monitoring program of tests and evaluations to
ensure that policies and procedures are appropriate and effective.

NARA Is Improving Its IT The Clinger- Cohen Act of 1996 requires agencies to
establish an IT Investment Management investment process that provides the
means for senior management to Processes obtain timely information regarding
the progress of investments in an information system, including a system of
milestones for measuring progress in terms of cost, timeliness, quality, and
the capability of the system to meet specified requirements. Weak IT
investment management

processes significantly increase the risk that agency funds and resources
will not be efficiently expended.

22 U. S. General Accounting Office, Information Security Management:
Learning from Leading Organizations, GAO/ AIMD- 98- 68 (Washington, D. C.:
May 1998).

The first step toward establishing effective investment management is
putting in place foundational, project- level control and selection
processes. These foundational processes allow the agency to identify
variances in project cost, schedule, and performance expectations; to take
corrective action, if appropriate; and to make informed, project- specific
selection decisions.

The second major step toward effective investment management is to
continually assess proposed and ongoing projects as an integrated and
competing set of investment options. This portfolio management approach
enables the organization to consider the relative costs, benefits, and risks
of new and previously funded investments and thereby identify the mix that
best meets its mission, strategies, and goals. NARA?s IT investment
management policies and processes were assessed

and reported on by its inspector general (IG) in April 2000. The report
identified several strengths in NARA?s IT investment management processes,
including having an IT investment board, a defined process for selecting
projects, criteria to be applied in considering whether to undertake a
particular IT investment, ratings of each investment?s breadth

of impact, and a determination of the net benefits and risks be identified
for proposed investments. However, the IG identified weakness and made 13
recommendations for strengthening NARA?s IT investment management

processes. NARA concurred with all recommendations. While it has to date
fully addressed only 2 of the recommendations, it plans to resolve the
remaining 11 issues by September 30, 2002.

While NARA?s investment management process has several strengths and NARA
continues to improve process weaknesses, NARA has yet to complete its
efforts to establish a mature investment management capability. Lacking a
fully mature investment management process

increases the risk that the electronic archival system will not be
implemented on time and within budget, and that crucial resources and funds
for meeting the electronic records challenges will not be invested
effectively and efficiently. Specifically, if NARA management?s oversight of
the ERA program is not based on complete information (including comparisons
of the actual cost and schedule to the estimated cost and schedule, as well
as identification of project risks and benefits), the risk is increased that
NARA management will not be able to determine whether the ERA program is
having schedule or other problems and ensure that corrective actions are
taken.

NARA Is Developing an The importance of enterprise architecture development,
implementation,

Enterprise Architecture and maintenance is a basic tenet of effective IT
management. Used in concert with other IT management controls, an enterprise
architecture can greatly increase the chances for optimal mission
performance. We have

found that attempting to modernize operations and systems without an
enterprise architecture leads to operational and systems duplication, lack
of integration, and unnecessary expense.

Over the past several years, NARA has taken action to develop an enterprise
architecture. NARA has drafted a current architecture and is working on a
target architecture, but this work is incomplete. 23 However, the process to
develop the electronic archival system is well under way. Without an
enterprise architecture to guide its development, NARA

increases the risk that the planned electronic archival system will be
incompatible with existing and future operations and systems, thus wasting
resources and requiring that unnecessary interfaces be built to achieve

integration. NARA Is Improving

NARA is currently strengthening its information security, having Information
Security, but

recognized that it has numerous weaknesses. Significant security Has Not Yet
Completed Key weaknesses were identified by two IG assessments (conducted in
fiscal Tasks years 2000 and 2001) and a NARA- initiated vulnerability
assessment of its network (performed concurrently with the IG assessments).
As a result of these assessments, the Archivist of the United States
declared information security a material weakness in fiscal year 2000. 24
Actions taken by the Archivist to addresses these shortcomings and respond
to recommendations identified in the reports include establishing an

information security program, updating and developing new security policy
documents, developing contingency plans and business recovery plans, and
strengthening firewalls across the network to control inbound and

outbound traffic. NARA said that it would implement the IG?s recommendations
by June 28, 2002, and by the end of fiscal year 2002 it plans to have
rectified the shortcomings that led to its information security being
declared a material weakness.

23 NARA?s effort to develop an enterprise architecture includes a separate
effort to develop a data architecture. 24 Fiscal Year 2000 Federal Managers?
Financial Integrity Assurance (FMFIA) Report to the President.

However, although NARA is making progress in strengthening its information
security, two additional weaknesses could affect the ERA program. First,
NARA currently lacks a program for assessing agencywide

information security risks. Federal guidance requires all federal agencies
to establish comprehensive information security programs based on assessing
and managing risks. 25 Risk assessments provide a basis for establishing
appropriate policies and selecting cost- effective techniques to implement
these policies. NARA intends to develop an agencywide risk assessment
capability in fiscal year 2003, but it is not clear that this will allow
vulnerability assessments to be completed before ERA is developed.

Without a method to identify and evaluate risks, NARA cannot be assured that
it has effective mechanisms for protecting its information assets: networks,
systems, and information associated with ERA. Because a compromise of
security in a single poorly secured system can undermine the security of
multiple systems, NARA needs to complete vulnerability assessments of all
systems that will interface with ERA.

Second, because NARA lacks an enterprise architecture, it may have
difficulty addressing agencywide security. Federal guidance calls for
agencies to make security controls for systems consistent with and an
integral part of the enterprise architecture of the agency. 26 Without an
enterprise architecture that addresses security issues agencywide, NARA
cannot be sure that its current or future archiving systems are adequately
protected. These weaknesses may be particularly significant for ERA, because
this system presents security issues that NARA has never before addressed,

according to an initial assessment report on ERA prepared by NARA?s systems
development and acquisition contractor. 27 The proposed distributed
structure of ERA introduces the security risks associated with the Internet-
threats to the integrity of data and to data accessibility. According to the
Federal Bureau of Investigation, Internet systems are threatened by hackers
(who may be terrorists, transnational criminals, and

25 Chapter 35 of title 44, section 1061, subchapter II- Information
Security, United States Code. 26 Office of Management and Budget,
Incorporating and Funding Security in Information Systems Investments,
Memorandum 00- 07 (Washington, D. C.: Feb. 28, 2000). 27 Integrated Computer
Engineering, Inc., Electronic Records Archives Initial Assessment Final
Report, version 1.2 (Oct. 18, 2001).

intelligence services) using information exploitation tools such as computer
viruses, worms, Trojan horses, logic bombs, and eavesdropping sniffers. 28
As Internet usage increases, the Internet has become an increasingly
tempting target, and the number of reported Internet- related security
incidents is growing. 29 The effect on ERA of the vulnerabilities of the
Internet would have to be assessed and addressed.

Conclusions In response to the challenges associated with managing and
preserving electronic records, NARA has performed an assessment of

governmentwide records management- an important first step that identified
several problems, including the inadequacy of guidance on electronic
records, the low priority generally given to records management, and the
lack of technology tools to manage electronic records. While NARA has plans
to improve its guidance and address the need for technology, it has not yet
formulated a strategy to deal with the stature of records

management programs across government. Further, it has no strategy for
acquiring the kind of comprehensive information on records management that
would be provided by systematic inspections and evaluations of federal
records programs. Without such a strategy, records management will likely
continue to be considered a low- priority ?support? activity

lacking appropriate management attention, and NARA will not acquire
information needed to address problems in agency records management and
guidance. Inadequacies in records management put at risk records that 28
Virus: a program that ?infects? computer files, usually executable programs,
by inserting a copy of itself into the file. These copies are usually
executed when an infected file is loaded into memory, allowing the virus to
infect other files. Unlike the computer worm, a virus

requires human involvement (usually unwitting) to propagate. Worm: an
independent computer program that reproduces by copying itself from one
system to another across a network. Unlike computer viruses, worms do not
require human involvement to propagate.

Trojan horse: a computer program that conceals harmful code. A Trojan horse
usually masquerades as a useful program that a user would wish to execute.
Logic bomb: in programming, a form of sabotage in which a programmer inserts
code that causes the program to perform a destructive action when some
triggering event occurs, such as termination of the programmer?s employment.
Sniffer or packet sniffer: a program that intercepts routed data and
examines each packet in search of specified information, such as passwords.
29 For example, the number of incidents handled by Carnegie- Mellon
University?s Computer Emergency Response Team (CERT) Coordination Center has
increased from 1, 334 in 1993 to 8, 836 during the first two quarters of
2000. Similarly, the Federal Bureau of Investigation reports that its
caseload of computer- intrusion- related cases is more than doubling every
year.

may be valuable: records providing information on essential government
functions, information that is necessary to protect government and citizen
interests, and information that is significant for the historical record.
NARA?s effort to acquire an advanced electronic records archive is at risk.
NARA is not meeting its schedule for the ERA system, largely because of
flaws in how the schedule was developed. As a result, the schedule will be
compressed, leaving less time for completing essential planning tasks. In

addition, NARA has not yet improved IT management capabilities that would
reduce the risks inherent in its effort to acquire ERA. Without these
capabilities, NARA risks spending funds to acquire a system that does not
meet mission needs and requirements, effectively work with existing systems,
or provide adequate security over the information it contains.

Recommendations for To address the low priority given to records management
programs across Executive Action

government, we recommend that the Archivist of the United States develop a
documented strategy for raising agency senior management awareness of and
commitment to records management principles, functions, and programs.
Further, we recommend that the Archivist develop a documented strategy for
conducting systematic inspections of agency records management programs to
(1) periodically assess agency progress in improving records management
programs and (2) evaluate the efficacy

of NARA?s governmentwide guidance. To mitigate the risks associated with the
acquisition of an advanced electronic archival system, we recommend that the
Archivist reassess the ERA project schedule. A revised schedule should be
developed, based on estimates of the amount of work and resources required
to complete each

task, that allows sufficient time for NARA to

 complete essential planning tasks and

 strengthen its IT management capabilities by (1) implementing an IT
investment management process, (2) developing an enterprise architecture,
and (3) improving information security.

Agency Comments and In written comments on a draft of this report, which are
reprinted in Our Evaluation

appendix V, the Archivist of the United States generally agreed with our
recommendations but provided clarifications concerning records

management priority, inspections, and the ERA schedule. NARA also provided
technical comments, which we have incorporated as appropriate.

The Archivist agreed with our recommendation that NARA develop a strategy
for raising agency senior management awareness of and commitment to records
management principles, functions, and programs, adding that the
responsibility for oversight of records management is not NARA?s alone, but
is shared by the Office of Management and Budget (OMB), the General Services
Administration (GSA), and the heads of federal agencies. Further, he
acknowledged that more needs to be done to have a major effect on agency
leadership. The Archivist, however, disagreed with our conclusion that NARA
does not plan to address the low

priority generally given to records management. Our conclusion was not meant
to imply that NARA does not intend to address the priority of records
management. We acknowledge NARA?s past efforts to raise awareness of the
importance of records management and its

stated plans to further address this issue. Instead, our conclusion reflects
the fact that NARA?s written plan to reform federal records management
policies and practices- which NARA refers to as its Records Management
Initiatives- does not currently address this issue. We believe that to be

successful, NARA must document its plans to address the low priority of
records management programs across government, including specific goals,
strategies, and milestones. Such a plan is critical in ensuring concurrence
on planned actions among the key players that NARA mentions, including
federal agencies, GSA, and OMB; that appropriate resources are assigned; and
that NARA has the means to track progress

against its goals. The Archivist also agreed with our recommendation that
NARA develop a strategy for conducting systematic inspections of agency
records management program, but noted that continuing its past inspection
program, as cited in the report, would not succeed. NARA disagreed with our
conclusion that it has no plans to address the issue of records

management inspections, noting that it plans to use risk management analysis
while leveraging its inspection resources. The Archivist said that this
approach would include an assessment of broad categories of important
records across agencies, agency- specific interventions, and the use of
NARA?s authority to report the results of evaluations of at- risk records to
OMB and the Congress.

We are not suggesting that NARA resurrect its past inspection program, which
it concluded was basically flawed. However, we also do not believe that
NARA?s current targeted assistance approach is an appropriate substitute for
systematic inspections and evaluations of federal records

programs. In regard to our conclusion, it is again based on the fact that
the written strategy for the Records Management Initiatives does not address
the need for systematic inspections. We acknowledge NARA?s statement that it
plans to use a risk- based approach to addressing this issue, but we
reiterate the need for a documented plan with associated goals, strategies,
and milestones.

In commenting on our recommendation that NARA reassess the ERA project
schedule, the Archivist stated that such a reassessment is prudent and that
NARA intends to conduct such reassessments repeatedly, both

periodically from an overall program management viewpoint and on a
continuing basis as part of its ERA risk management activity. The Archivist
noted that NARA is currently reassessing the schedule as part of its
refinement of the ERA acquisition strategy, and that this reassessment will
address the issues raised in our report.

Regarding the schedule for the ERA system, the Archivist noted that while
some program documentation was not completed on schedule, all items on the
ERA project?s ?critical path? have been completed on time, and NARA expects
to meet all milestones on the critical path this year. We disagree. As
discussed in our report, the development of key program documents- such as
the ERA vision statement and the concept of operations- were affected by
delays. For example, the ERA vision statement, planned for completion on
March 1, 2002, was not completed until April 18, 2002, approximately 6 weeks
late. Similarly, the concept of operations, due on April 1, 2002, and

which NARA documentation shows as being on the critical path, was delivered
in draft form on that date and had not been finalized as of May 31. Falling
behind schedule in the initial stages presents risks to successful and
timely completion of the ERA project and is one of the reasons we are
recommending that the agency reassess its schedule. The Archivist also
disagreed with our conclusion that if the results of the

two National Academy of Sciences assessments are not fully reflected in the
ERA requirements, there is added risk that the technical strategy underlying
the development of the system will prove not to be optimal, and that
alternatives will not have been considered. The Archivist noted that NARA
should receive the first National Academy of Sciences report at a time when
it expects to receive the industry?s response to NARA?s request

for information, and that the report will provide an unbiased, expert view
of the feasibility of building a system that is inherently evolutionary,
addressing the core problem of digital preservation. According to the
Archivist, NARA will factor both the scientific and the industry views into
its articulation of a draft request for proposals. In regard to the second

National Academy of Sciences report, the Archivist noted that its primary
purpose is to provide input to NARA?s long- range plans for addressing the
continuing evolution of information technology and electronic records, and
that the report will be useful in revising the ERA research plan to address
new problems and opportunities identified by the experts, and in plans for
successive builds of the ERA system.

We acknowledge NARA?s clarification regarding the timing and use of the two
NAS studies and believe this approach should assist in developing a system
that will meet mission needs. Accordingly, we have revised our
recommendation to reflect this.

We are sending copies of this report to the Ranking Minority Member,
Subcommittee on Government Efficiency, Financial Management and
Intergovernmental Relations, House Committee on Government Reform, and to
the Ranking Minority Member, Subcommittee on Treasury, Postal Service and
General Government, House Committee on Appropriations. We are also sending
copies to the Archivist of the United States, the Secretary

of Housing and Urban Development, the Secretary of State, the Secretary of
Commerce, the Secretary of Veterans Affairs, and the Administrator of NASA.
This report will also be available on GAO?s home page at http:// www. gao.
gov. If you have any questions concerning this report, please call me at
(202) 512- 6240 or Mirko J. Dolak, Assistant Director, at (202) 512- 6362.
We can also be reached by E- mail at koontzl@ gao. gov and dolakm@ gao. gov,
respectively. Key contributors to this report were Timothy Case, Barbara
Collier, Jamey Collins, David Plocher, and Megan Savage.

Linda D. Koontz Director, Information Management Issues

Appendi Appendi xes x I

Objectives, Scope, and Methodology Our objectives were to

 determine the status of NARA?s efforts to respond to governmentwide
electronic records management problems and the adequacy of its future plans
and

 assess NARA?s efforts to acquire an archival system for electronic
records.

As part of our assessment of NARA?s efforts to acquire an electronic records
archiving system, we were also asked to identify alternative technologies
under consideration for the long- term preservation of electronic records.

To determine the status of NARA?s efforts to assess and respond to
governmentwide electronic records management problems and the adequacy of
its future plans, we reviewed federal legislation and NARA records
management guidance, available studies, and reports; surveyed NARA?s
appraisal archivists working with federal agencies; reviewed records
management activities and obtained the views of record managers in selected
federal agencies managing large volumes of electronic

records- the Departments of State, Commerce, Housing and Urban Development
(HUD), and Veterans Affairs (VA), as well as NASA and the Patent and
Trademark Office; and reviewed legal challenges to federal electronic
recordkeeping practices, including Public Citizen v. John Carlin and Scott
Armstrong v. Executive Office of the President. We also reviewed NARA?s
documentation of its effort to redesign its approach and guidance for the
management of electronic records. As part of this effort, we investigated
whether agencies are scheduling their major information systems and the
related databases; to do so, we asked five major agencies- Commerce, HUD,
VA, State, and NASA- what portion of their

major information systems were scheduled and placed under the agency records
management program. We based our assessment on the inventory of Year 2000
mission- critical systems reported by 24 major agencies to the

Office of Management and Budget. 30 In addition, to determine the status of
the Library of Congress? National Digital Information Infrastructure and
Preservation Program and its relationship to NARA?s efforts to design and 30
Subcommittee on Government Management, Information, and Technology, House
Committee on Government Reform, Federal Government Earns a B+ on Final Y2K
Report Card, news release (Washington, D. C.: Nov. 22, 1999).

acquire advanced electronic archival system, we discussed the program?s
objectives and schedule with Library of Congress officials.

To assess NARA?s efforts to acquire an archival system for electronic
records, we reviewed agency and contractors? documentation for the
electronic records archive (ERA) program, including program and project
phasing; on the basis of federal requirements and information industry

practice, we assessed NARA?s effort to develop or enhance its information
technology capabilities, including information technology investment
management, enterprise architecture, and information security. To identify
alternative technologies under consideration for the long- term

preservation of electronic records, we reviewed archival studies and
literature, and we surveyed selected digital preservation approaches used by
the information industry and selected national governments. In addition, we
contacted the archives of three judgmentally selected foreign countries
(Australia, Canada, and the United Kingdom) that had been identified by
records management professionals as using advanced electronic records
management and that we had previously reviewed. 31 We also contacted the
Public Record Office of Victoria, Australia; although this archive is not at
the scale of a national archive, we included it because it has employed a
unique technological approach to archiving electronic records.

We performed our work from June 2001 to May 2002 in accordance with
generally accepted government auditing standards. 31 U. S. General
Accounting Office, National Archives: Preserving Electronic Records in an
Era of Rapidly Changing Technology, GAO/ GGD- 99- 94 (Washington, D. C.:
July 19, 1999) (http:// www. gao. gov/ archive/ 1999/ gg99094. pdf).

Approaches to Archiving Electronic Records

Appendi x II

Provide Partial Solutions The challenge of managing and preserving the vast
and rapidly growing volumes of electronic records produced by modern
organizations is placing pressure on archives and on the information
industry to develop a costeffective long- term preservation strategy that
will free electronic records from the constraints of proprietary file
formats and software and hardware

dependencies. Part of this strategy will involve ways to capture and use
information about the records to make them accessible, as information in
card catalogs does in traditional libraries. After considerable research in
this area, some agreement is being reached on the metadata (data about data)
required for preserving electronic records, and some practical applications
are using XML (Extensible Markup Language 32 ) for creating

such metadata. However, there is no current solution to the electronic
records archiving challenge, and so archival organizations now rely on a
mixture of evolving approaches that generally fall short of solving the
long- term preservation problem. The four most common approaches- migration,
emulation, encapsulation, and conversion- are in use or under consideration
by the major archives. NARA is supporting the investigation of a new
approach involving records conversion (known as persistent object
preservation), but this has yet to mature.

Recognizing that archival solutions may be some time off, companies in the
information industry are relying on off- the- shelf technology for providing
access to billions of electronic records. These commercial archives,
however, concentrate on electronic records of types that are relatively
uniform in comparison to those that a government archive must address.
Archiving Requires Archives use catalogs of various types to capture
information about

Documentation of records, information that is critical for sharing, storing,
managing, and Attributes and Relationships

accessing records effectively- particularly in the context of millions of of
Records records. Because such information is data containing descriptive
information about other data, it is referred to as metadata. Metadata are a

central element of any approach to ensure that preserved records are
functional. For electronic records, the metadata needed are often more
extensive than information in traditional catalogs, including information
that is important for preservation. 32 XML is a simplified subset of the
Standard Generalized Markup Language (SGML) used to define portable document
formats.

Metadata Provide Information The creation of accessible software- and
hardware- independent electronic Necessary to Describe records requires that
all materials that are placed in archives be linked to Electronic
Collections information about their structure, context, and use history.
Metadata to be

associated with electronic records may include information about

 the source of the record;

 how, why, and when it was created, updated, or changed;

 its intended function or purpose;

 how to open and read it;

 terms of access, and

 how it is related to other software and records used by the originating
organization.

These metadata must be sufficient to support any changes made to records
through various generations of hardware and software, to support the
reconstruction of the decisionmaking process, to provide audit trails
throughout a record?s life cycle, and to capture internal documentation.

Without an adequately defined metadata structure, an effective electronic
archive cannot be constructed.

Numerous research projects have examined the question of defining metadata
that would be sufficient to ensure digital preservation. Although archives
experts note that unresolved issues remain, the work on preservation
metadata is beginning to move from the research area to practice. The Public
Record Office Victoria (Australia), a state archive, has published standards
for the management of electronic records that

includes a metadata model originally developed by the National Archives of
Australia.

For incorporating metadata, the Victoria archive mandates the use of XML.
XML is being actively considered by archives and researchers as a promising
approach to generating metadata.

XML Enables InfrastructureIndependent XML is a flexible, nonproprietary set
of standards for annotating

Description of (? tagging?) data with semantically rich labels that permit
computers to Electronic Records

process files on the basis of their meaning. 33 Like the more familiar HTML
(Hypertext Markup Language) files used on the World Wide Web, XML files can
be easily transmitted via the Internet, and with appropriate software, they
can be displayed by Web browsers. The difference is that HTML is used only
for telling computers how to display information for a human being to view,
whereas the semantically based XML tags allow computers to automatically
interpret and process XML files. XML is called extensible because it is not
a fixed format. Instead, XML is actually a ?metalanguage?- a language for
describing other languages-

which allows the design of customized markup languages for limitless
different types of documents. Thus, although in the beginning stages of
adoption, XML is viewed as a promising format for a wide range of
applications. 34 Several XML attributes make it attractive for archive
applications. The semantic nature of XML tags makes XML suitable for
recording metadata. Its extensibility would allow archives to expand their
systems to accommodate evolving needs. As an open standard, it reduces the

problems of proprietary software. Further, because they are basically text
files, XML files can be readily interpreted by disparate computer systems.
Even without the mediation of software, human beings can interpret an XML-
tagged file, because XML tags are human readable (see fig. 4). This

quality allows them to be preserved both on computer media and on paper (so
that they would be readable both by human beings and automatically through
optical character recognition). 33 Tagging data in a standard way allows any
system that recognizes the standard to readily understand and process data
that conform to that standard. In tagging, a standard format is used to
label each element of a data set with metadata that clarify what kind of
information is being provided. Common tagging systems for electronic
information- also known as markup languages- use labels set off by angled
brackets to show where data elements begin and end: for example, in data ,
the second tag includes a slash to indicate that it is a closing tag. 34 U.
S. General Accounting Office, Electronic Government: Challenges to Effective
Adoption of the Extensible Markup Language, GAO- 02- 327 (Washington, D. C.:
Apr. 5, 2002).

Figure 4: Sample of XML Version of State Department Telegram

Source: San Diego Supercomputer Center.

Figure 4 is an example of a text document- a World War II vintage telegram
in the Franklin D. Roosevelt library- converted to XML format. 35 The XML

?tags? provide the means for identifying- and retrieving- key pieces of
information, such as date sent, addressee, and place of sender. If the file
were viewed in an XML- compliant Web browser, the tags in the telegram would
not be visible, and the telegram itself could be displayed in various

ways for the convenience of the human reader. At the same time, the presence
of the tags permits computer systems to perform powerful searches and
exchange data.

XML is also used by the National Archives of Australia, 36 which converts
files from their native formats to XML versions, while retaining a copy of
the original source file. The Australian archives has also developed a
metadata model, but it has not yet determined its final preservation
metadata requirements. Electronic Archives Take For long- term preservation
of electronic records, electronic archives must Combinations of address the
problems of obsolescence and aging of storage media, the Approaches to
Preservation

dependence of electronic records on the software and hardware on which they
were created, the complexity of electronic records, and the massive volumes
of records created by often decentralized systems. According to one archival
expert, a viable strategy for long- term preservation for electronic records
would call for ?a long- lived solution that does not require continual
heroic effort or repeated intervention of new approaches every time formats,
software, or hardware paradigms, document types, or recordkeeping practices
change.? 37 Since no one solution is yet available that addresses all the
problems, most archives and other institutions that preserve records use a
variety of approaches, often in combination. The current approaches for
dealing with the technical issues associated with long- term electronic
archiving are

35 Amarnath Gupta, Preserving Presidential Library Websites, San Diego
Supercomputer Center, SDSC TR- 2001- 3 (Jan. 18, 2001). 36 National Archives
of Australia (http:// www. naa. gov. au/).

37 Jeff Rothenberg, Avoiding Technological Quicksand: Finding a Viable
Technical Foundation for Digital Preservation, Council on Library and
Information Resources (January 1999) (http:// www. clir. org/ pubs/ reports/
rothenberg/ contents. html).

 technology preservation- maintaining old technologies to allow access to
old formats;  emulation- using software running on new- technology
platforms to

mimic old technologies;

 migration- transferring digital materials from one hardware/ software
configuration to another, or from one generation of computer technology to a
subsequent generation; 38  encapsulation- grouping together a digital
object with other

information necessary to provide access to that object; and

 conversion to standard formats- transforming records into objects that are
relatively software and hardware independent. The recent development of
durable analog storage media (that is, media that preserve images of human-
readable documents, much as microfiche does) suggests the possibility of
approaches that combine those above with the use of analog rather than
digital media. 39

Technology Preservation Is a Technology preservation refers to the practice
of maintaining outdated

Short- Term Solution Only equipment well after it is useful in everyday
business processes. Under this approach, electronic files or records, which
are saved in their native formats, continue to be accessible through the use
of original hardware and software. In the short term, this is a simple and
cost- effective approach, and some organizations do maintain older
information systems only to be able to access their records. 40

However, this approach is at best an interim solution to the problem of the
dependence of electronic records on the software and hardware on which they
were created. The solution eventually fails, because maintaining the

38 Task Force on Archiving of Digital Information, Preserving Digital
Information (May 1, 1996) (http:// www. rlg. org/ ArchTF/).

39 HD- Rosetta Archival Preservation Services (http:// www. norsam. com/
hdrosetta. htm).

40 Andrew Waugh, Ross Wilkinson, Brendan Hills, and Jon Dell?oro, Preserving
Digital Information Forever, Commonwealth Scientific and Industrial Research
Organisation (CSIRO) Mathematical and Information Sciences (undated)
(http:// pigfish. vic. cmis. csiro. au/~ ajw/ PresDigitInfoL. pdf).

original technology grows increasingly difficult and costly with the passage
of time. Further, it does not solve the problem of aging and obsolescent
storage media, which would also grow more difficult if not impossible to
replace. Issues of cataloging and metadata are also not addressed by this
approach. With the seemingly endless introduction of new hardware and
software, the sheer number of differing formats and applications, and the

cost to maintain any and all systems, technology preservation is not a
feasible strategy for the long term.

Emulation Is Currently More A proposed approach to the problem of software
and hardware Theoretical Than Practical for dependence is emulation, which
aims to preserve the original software Electronic Archiving environment in
which records were created. Emulation software mimics the functionality of
older software (generally operating systems) and

hardware. Under the emulation approach, data files are stored along with
copies of the creating software as well as software that emulates the
hardware/ operating system required to run the software. 41 This technique
seeks to recreate a digital document?s original functionality, look, and
feel by reproducing, on current computer systems, the behavior of the older

system on which the document was created. In other words, an emulation
strategy means that nothing is done to the original electronic file; rather,
the original environment is recreated. Since the original file remains
unaltered, emulation also offers a solution to the problem of preserving the
original functionality and the ?look and feel? of complex digital files.
Emulation has been in practical use on computer systems for many years:

 IBM mainframes emulate previous mainframes in order to support legacy
systems and allow several generations of operating system versions to be
run.

 Operating system emulators allow a single computer to provide more than
one operating environment (such as Macintosh and Windows).

 Emulation software allows desktop computers to run video games and legacy
video gaming systems.

41 Jeff Rothenberg, Using Emulation to Preserve Digital Information,
Position Paper, NSF Workshop on Data Archiving & Information Preservation
(Mar. 26, 1999) (http:// cecssrv1. cecs. missouri. edu/ NSFWorkshop/
ppaper3. html).

However, according to one archival expert, emulation has not yet been
applied to preserving archival documents in any systematic way. Although
emulation could in theory be part of a solution to the problem of hardware
and software independence, it is just beginning to be explored as an

archival approach. Emulation is under consideration as one of various
archiving approaches by the United Kingdom?s Public Record Office. 42 One
problem unique to emulation is that intellectual property rights issues may
be involved when either operating systems or applications are emulated. 43
Even if the software and hardware are obsolete, their copyrighted
specifications are not likely to be released for the benefit of archival
integrity. Further, the use of an emulated operating system or application
introduces outmoded programs into a modern environment, requiring users to
understand how to use them; in other words, using the

old software may require expert knowledge of the outdated systems- knowledge
that is likely to disappear.

Other problems with emulation include the increasing possibility that
software failures will occur as the old systems continue to age and the pool
of expertise concerning them shrinks. Emulation assumes that the

emulated software will continue to run without maintenance. As the year 2000
date conversion problem showed, this is not a safe assumption, as it is
possible that software may contain bugs that may eventually cause
catastrophic loss of information. 44 Further, an emulation approach depends
on several components working together (the emulation software, the original
application, and the data); as the number of components increases, so does
the risk of failure. Migration of Both Media and File

Migration refers to the periodic transfer of digital materials from one
Formats May Preserve Records

format configuration to another, or from one generation of computer
technology to a subsequent generation. In the context of archiving,
migration can refer both to the media on which information resides
(conversion from older to newer media or forms of media) and to the 42 The
Public Record Office is the national archive of England, Wales, and the
United Kingdom (http:// www. pro. gov. uk/).

43 Jeff Rothenberg, Using Emulation to Preserve Digital Documents, Rand-
Europe, Koninklijke Bibliotheek (The Hague: July 2000). 44 See footnote 40.

formats in which it is encoded (conversion from one file format or system to
another).

The first type of migration, media migration, has been so far unavoidable:
it is the standard approach to the problem of media obsolescence and aging.
In media migration, records are moved from older storage media to newer
media, either to avoid the obsolescence or decay of an older medium or to
upgrade to a more advanced medium (often to increase storage capacities
while reducing cost). However, media migration alone does not ensure that
the electronic records transferred to the new media continue to be

accessible, especially if their format is obsolete. As new storage
technologies evolve- including extreme- longevity analog media such as the
High Density Rosetta disk discussed later in this appendix- the migration
process may become less frequent and more efficient.

The second type of migration, format migration, is a process of preservation
by conversion: specifically, format migration is defined as rearranging the
original sequence of structural and data elements of a file to conform to
another configuration. Such migration occurs whenever older systems and
formats are displaced by newer, often more advanced systems and formats.
Many organizations have, for example, converted old database systems to
newer systems, and in the process they have converted the formats of the
records they contain.

The major difficulty with format migration is the risk of altering records
during conversion from the source to the target format. For conversions to
be successful, those performing the transition must have knowledge of the
original application and data formats, 45 and the more complex the file
structure, the more important this knowledge is. Whether the application is
commercial or generated in house, over time this knowledge may be lost

and with it the ability to perform a successful migration. For such reasons,
migration has been described as cost effective only for certain types of
records that remain in operational use. 46 For records in use, problems with
imperfect conversion are more likely to be discovered by users, and
organizational resources are more likely to be devoted to ensuring that
these are resolved or mitigated.

45 See footnote 40. 46 See footnote 40.

Further, although format migration has occurred in many contexts in the
past, it has not been extensively used in archiving. Most electronic
archives are relatively new, so they are dealing with records in current
formats created by systems that are still operational. Thus, they have not
yet experienced the need to incorporate format migration into their
processes. Rather, they treat migration as a future option for dealing with
preserving

the types of records that they are currently storing. As a strategy for the
long- term preservation of electronic records, relying on format migration
is risky. Migration as a preservation strategy would have to be a continuous
process, with conversions occurring whenever a new format needed to be
introduced. With each format conversion, the

possibility of loss would be increased, and the more complex the record, the
more the possibility of loss. Thus, migration is at best an imperfect
solution as it can potentially lead to the loss of record integrity.
Migration was selected by the United Kingdom?s Public Record Office as its

current archival approach. In addition to migration, the Public Records
Office is also considering using emulators and viewers to access archived
files in their native formats. Encapsulation Preserves Both

Encapsulation is the combining of several elements to create a new single
Records and Information about entity; in the context of archiving, the
elements would be the records Records themselves, metadata identifying and
describing the records, and possibly other elements (such as viewers
enabling the records to be read). 47

Unlike migration, encapsulation does not necessarily involve a change in the
original file format. If the format is unchanged, encapsulation would avoid
the problem of loss of integrity that migration entails. Leaving records in
their native formats would leave open the possibility of processing the
objects with the original software, and it would also permit subsequent
transformation of the encapsulated records using methods that were not
available when the records were originally placed into the archives. 48

47 Encapsulation, Preserving Access to Digital Information (PADI) (http://
www. nla. gov. au/ padi/ topics/ 20.html).

48 Ken Thibodeau, ?Building the Archives of the Future: Advances in
Preserving Electronic Records at the National Archives and Records
Administration,? D- Lib Magazine (February 2001) (http:// www. dlib. org/
dlib/ february01/ thibodeau/ 02thibodeau. html).

Encapsulation is currently being used by the Victoria Public Records Office
in Australia. 49 The Victoria archive uses XML to encapsulate records along
with standardized metadata describing each record in a Victorian

Electronic Record Strategy (VERS) format. 50 The VERS format mandates the
use of XML to describe and encapsulate records. However, the Victoria
archive has only recently begun applying its process, and its electronics
records collection is as yet small (described as ?a few records?), so it is
premature to judge its effectiveness for large- scale, long- term
preservation. Conversion to Standard Formats

Conversion transforms records into standard text formats such as ASCII 51
Makes Records Less Dependent or XML to increase their independence from
hardware and software. This on Hardware and Software approach is currently
used by the National Archives of Canada 52 and by NARA (both of which accept
databases in ASCII format), as well as the

National Archives of Australia, 53 which converts files from their native
formats to XML, while retaining a copy of the original source file. The
Victoria archives is using a combination of conversion and encapsulation in
its preservation approach, because before encapsulating selected types of
documents, it is requiring their conversion (where appropriate) to Adobe
Systems? Portable Document Format (PDF). PDF is a compact format that
preserves all the fonts, formatting, graphics, and color of any source
document, regardless of the software and hardware used to create it.
Although PDF is a proprietary file format, PDF files can be

shared, viewed, navigated, and printed exactly as intended by anyone with
the freely distributed Adobe Acrobat Reader.

The primary shortcomings of the conversion approach are the limitations and
the longevity of the selected standard. 54 For example, converting databases
to ASCII format limits their usefulness: the conversion of a 49 Public
Records Office Victoria (http:// www. prov. vic. gov. au/ welcome. htm).

50 The metadata are based on a model developed by the National Archives of
Australia. 51 The ASCII character set of 128 characters includes the
familiar letters, numbers, and punctuation of the roman alphabet, along with
certain other characters such as spaces, tabs, and carriage returns.

52 National Archives of Canada (http:// www. archives. ca/).

53 National Archives of Australia (http:// www. naa. gov. au/).

54 See footnote 40.

relational database to flat ASCII database tables will eliminate the
embedded information about the relationships among data elements. 55
Conversion to XML, on the other hand, may involve fewer such limitations,
but it depends on the XML standard remaining in use and accessible. NARA is
investigating an advanced form of conversion combined with encapsulation
known as persistent object preservation (POP). Under this approach, records
are converted by XML tagging and then encapsulated with metadata. According
to NARA, the persistent object transformation approach would make electronic
records self- describing in a way that is independent of specific hardware
and software. The architecture for POP

is being developed through the National Partnership for Advanced
Computational Infrastructure. The partnership is a collaboration of 46
institutions nationwide (including NARA) and 6 foreign affiliates, with the

San Diego Supercomputer Center serving as the technical resource. According
to NARA, persistent object preservation would accommodate preservation of
persistent but evolving collections by providing the ability to dynamically
reconstruct data collections on new technology. The result would be a system
that could upgrade individual technical components and

migrate media while safeguarding the archived records. POP would thus not
only enable the use of future, advanced technologies, it would also reduce
threats to integrity and authenticity, because POP would not require changes
in the preserved data. However, POP may not be sufficiently mature to be
translated into system design.

Migration to Durable Analog An archive that stores records digitally must
use media migration as a Media May Offer Hybrid preventive measure to avoid
decay and obsolescence. However, the use of Approach

analog storage offers a possible alternative that may diminish the need for
media migration. Whereas all current media now record digital information as
0?s and 1?s, analog storage of documents is suggested by a new product,
called a High Density Rosetta, developed by Norsam Technologies (see

fig. 5). 55 A relational database allows the definition of data structures
and storage and retrieval operations. In such a database the data and
relations between them are organized in tables.

A table is a collection of records and each record in a table contains the
same fields. Certain fields may be designated as keys, which means that
searches for specific values of that field will use indexing for increased
speed. Interdependencies among these tables are expressed by data values.

Figure 5: The Long Now Foundation Rosetta Disk Language Archive

Source: Rolfe Horn, courtesy of the Long Now Foundation.

The nickel- plated disk, which has a life expectancy that is orders of
magnitude longer than current electronic media, 56 allows the analog storage
of information and images that are readable via an electron or optical
microscope. Such a medium could avoid the obsolescence created by software-
reliant media. The plates are physically inscribed by an ion

56 The manufacturer claims a life expectancy of at least 1, 000 years and a
temperature threshold of 500ï¿½ C.

beam, through a process known as ion milling. 57 This medium can store on
each side of its 2- inch plate over 196,000 pages (with electron microscope
retrieval) or 5,000 to 18, 000 pages (with optical microscope retrieval).
Using a text- based coding system such as XML would permit both coded

(software readable) and image (human readable) information to be stored on
this long- lived medium. The migration issue would then arise if new
software were to be adopted, but the image information would persist. The
High Density Rosetta is being used by the Long Now Foundation to create an
extreme- longevity archive of selected languages. 58 According to the
foundation, 50 to 90 percent of the world?s languages are predicted to
disappear in the next century, many with little or no significant
documentation. As part of the effort to secure this critical legacy of
linguistic diversity, the foundation initiated the Rosetta Project, 59 an
effort to develop a contemporary version of the historic Rosetta Stone. The

project?s goal is the development of a permanent archive of 1,000 languages.
For storage of this archive, the project is using the High Density Rosetta
to micro- etch text of archived languages at a scale readable by a 1,000-
power optical microscope.

Information Technology While government and academic institutions are
searching for a permanent

Industry Relies on Off- theShelf solution to electronic records archiving
problems, the private sector, also

Technologies to concerned about and affected by the potential loss of
electronic records, Provide Access to relies on existing information
architectures and off- the- shelf technologies

to make accessible massive volumes of electronic records dating back over
Electronic Collections

two decades. These archiving achievements do not meet the rigorous
requirements for permanence and authenticity that are demanded by a
government archive, nor are their owners required to process, store, and
access the full range of complex file formats encountered by governments.
However, they do illustrate the capability to provide storage and access to
large quantities of data. Two of the most notable private sector efforts are
the Internet Archives and the Google archive of Usenet messages.

57 Ion milling is an etching process in which high- energy gallium ions
produced by a focused ion beam machine knock atoms from the surface and
micro- engrave into any given medium. 58 The Long Now Foundation (http://
www. longnow. org).

59 The Rosetta Project (http:// www. rosettaproject. org: 8080/ live).

Internet Archives The Internet Archives has created a digital library of
Internet sites and other born- digital cultural artifacts. It is attempting
to archive the entire publicly available Web, offering free access to
researchers, historians,

scholars, and the general public. Anyone with access to the Internet can,
through the Internet Archives Web site, 60 navigate the Web at any moment in
time from 1996 to the present. This collection of Web pages contains

over 100 terabytes, or 10 billion Web pages, and it is currently growing at
a rate of 12 terabytes per month. The stored and accessible 100 terabytes is
larger than the amount of data contained in the world?s largest libraries,
including the Library of Congress, making it the largest known database in
existence. Without the efforts of the Internet Archives, these 10 billion
Web

pages might have been lost. As it is, they provide a record of the origins
and evolution of the Internet, as well as a reflection of societal interests
and opinions at different moments in time. This is particularly true in the
case of Web sites such as those of presidential candidates (see fig. 6) and
of monumental events such as the September 11 attacks, both of which have
prominence on the Internet Archives Web site as ?Special Wayback

Collections.? 60 Internet Archives (http:// www. archive. org/).

Figure 6: Internet Archive Collection of Presidential Candidate Web Sites

Source: Internet Archives.

According to the Internet Archives, it has achieved inexpensive storage on a
major scale: it uses off- the- shelf technology at a cost of about $4, 000
per terabyte. As a preservation strategy, the Internet Archives currently
uses media migration to avoid media obsolescence and take advantage of
technological advances to reduce costs. As a safety measure, backup copies
of a part of the collection are also created.

Google Google claims to have the largest index of Web sites available on the
World Wide Web and the industry?s most advanced search technology. Google?s
Web site also contains an archive of Usenet messages that cover the past 20
years (see fig. 7). 61 Usenet is a collection of text messages that are
posted on Internet electronic bulletin boards. These bulletin boards- which

61 Google Groups (http:// www. google. com/ grphp? hl= en).

existed before E- mail, Web browsers, and the Web itself- provide avenues
for communication in an open forum, allowing others to read and reply. Some
notable ?posts? included in Google?s Usenet Archives are the first post
mentioning Microsoft (1981), the first post mentioning a compact disc
(1982), and the posts sent just after the September 11 attacks.

Figure 7: Google?s Usenet Archive

Source: Google.

Google currently provides access to more than 700 million messages dating
back to 1981, and this number is rapidly increasing. Google?s collection is
by far the most complete collection of Usenet articles ever assembled.

Before Google?s acquisition of the archive, posts without activity were
usually deleted from the live discussion forums after a few days or weeks,
and therefore they were not viewable or searchable by users. Some feel

that Google?s Usenet archive is an irreplaceable and invaluable reference,
representing ?the human side of the Internet? through first- hand accounts
of historical events.

NARA?s Electronic Records Guidance Has

Appendi x II I Evolved A review of the development of electronic records
guidance issued by the National Archives and Records Administration (NARA)
over the last several decades demonstrates the extent to which the rapid
evolution of information technology has posed significant challenges for
NARA in its

role of providing guidance to federal agencies concerning the management of
electronic records under the Federal Records Act. 62 NARA provides guidance
for electronic records management and

disposition largely through two sets of guidance:

 the electronic records management regulation, which provides general
responsibilities for agency management of electronic records; 63 and

 the general record schedules, which provide disposal authorization for
specific categories of temporary records common to most agencies. 64

The history of these two sets of guidance reflects the evolution of NARA?s
electronic records guidance.

Electronic records management was given a formal role in 1968 when NARA,
then the National Archives and Records Service (NARS) of the General
Services Administration (GSA), established a unit to develop

policies for selecting and preserving electronic records. This Data Archives
Staff undertook to develop three sets of guidance: (1) inventory guidance-
forms for inventorying magnetic tape files; (2) environmental guidance-
recommendations for proper handling and storage of magnetic tape; and (3)
GRS 20- a general records schedule for computerized records.

Of that guidance, GRS 20 emerged as NARA?s first significant electronic
records guidance. It was intended to cover electronic records created by
mainframe applications in the then- dominant agency data processing
operations. The major purpose was to address the efficient disposition of
those electronic records, including destruction of unneeded temporary

records and transfer to NARS (NARA) of permanent records. 62 44 U. S. C.
chapters 21, 29, 31, and 33. 63 36 CFR Part 1234. This rule is supplemented
by NARA?s Records Management Handbook and periodic guidance on specific
issues, e. g., NARA Bulletin No. 2000- 02 (Dec. 27, 1999). 64 GRS 20 (August
1995).

The 1972 GRS 20, entitled Data Automation Program Records, stated,

?This schedule covers machine readable records, related documentation
required for their servicing, and files related to the automatic data
processing (ADP) procurement, operations, and management functions.? GRS 20
divided these records into categories that ?correspond roughly to the
typical organizational and functional structure found in most ADP

installations and their parent organizations.? 65 According to recent NARA
summaries, the 1972 GRS 20 was meant ?to provide disposal authority for
specific categories of temporary records associated with mainframe
applications. Excluded from its coverage, and

all subsequent revisions, were the types of records generated by large data
systems that might have archival value.? 66 The clear meaning of the 1972
GRS 20, however, was that it was not meant merely to identify and provide
for efficient disposal of ?ancillary materials common to most data
processing operations.? 67 Quite the contrary, the guidance identified a

range of records that should be scheduled through filing of a Standard Form
115. These ranged from various temporary records to potentially permanent
records, such as master data files.

GRS 20 was revised in 1977. 68 While the 1977 revision restructured the 1972
electronic records categories, it retained the earlier purpose of providing
disposition instructions for virtually all records associated with data
processing operations- temporary and permanent, program and administrative.
69

In 1983, GSA issued Bulletin FPMR B- 127, Archives and Records, which
provided guidance on records created or maintained ?using personal computers
and electronic information storage or transmission equipment

65 GRS 20, Data Automation Program Records, FPMR 101- 11.4 (Apr. 28, 1972).
66 GRS 20 (August 1995). 67 History of General Records Schedule 20,
Electronic Records (www. nara. gov/ records/ grs20/ 20hist. html).

68 GRS 20, Machine- Readable Records, FPMR 101- 11. 4 (Feb. 16, 1977). 69
Administrative records are those created in the performance of common
facilitative functions that support an agency?s mission activities, but do
not directly document the performance of mission functions. Administrative
records are temporary. Program records are those created in the performance
of the unique functions that stem from an agency?s

mission. Program records may be temporary or permanent; they must be
scheduled.

(electronic filing and electronic mail).? 70 According to the bulletin, ?The

proliferation of personal computers in many Federal agencies and the
implementation of sophisticated electronic filing and/ or mail systems has
created a need for adaptation of traditional records management techniques
for the control and disposal of records and information.? The

bulletin then reiterated that the disposition of all records regardless of
physical form is controlled by the Federal Records Act and instructed
agencies to ensure ?that appropriate internal controls are instituted to
prevent the loss or alienation of official records created or acquired in
electronic form.? Two pieces of similar guidance followed in 1985. First,
NARA issued Bulletin 85- 2 to provide general guidance ?on how to manage
records

created, stored, or transmitted using personal computers or other electronic
office equipment including word processors.? 71 This bulletin again rooted
electronic records management in the fundamental requirements of the Federal
Records Act: ?The creation, maintenance, and

disposition of all official records regardless of physical form is
controlled by the provisions of [the Federal Records Act and implementing
regulations].?

Two weeks after issuing Bulletin 85- 2, NARA issued an ADP Records
Management regulation. 72 This rule was the first version of the regulation
still found at 36 CFR 1234. The rule consolidated guidance consistent with
the goals of the 1968 Data Archives Staff, requiring each agency (in very
summary terms) to

 establish a program for the management of ADP records, including
classifying, preserving, and scheduling machine- readable records; and

 ensure proper care, handling, and storage of magnetic computer tapes and
disk packs. The next major step in the evolution of NARA?s electronic
records guidance occurred in the 1988 revision of two general records
schedules: GRS 20, now entitled Electronic Records, and GRS 23, Records
Common to Most 70 GSA Bulletin FPMR B- 127 (June 17, 1983).

71 NARA Bulletin No. 85- 2 (June 18, 1985). 72 36 CFR 1234, 50 FR 26939
(June 28, 1985).

Offices within Agencies. 73 The revisions significantly modified the scope
of both general records schedules and, for the first time, provided disposal
authority for personal computer records in GRS 23.

With regard to GRS 20, the 1988 revision altered its scope, stating, ?This

schedule applies to disposable electronic records routinely stored on
magnetic media by Federal agencies in central data processing facilities.?
As opposed to the broad purpose of the 1972 and 1977 versions, which had
been to provide disposition guidance for all electronic records associated
with data processing operations, the 1988 GRS 20 discussed only disposable
records. All references to scheduling records were removed. This change was
not limited, however, to GRS 20. It reflected a NARA decision that all
general records schedules should pertain only to disposable records. The
intent was to rely on other guidance to provide

instructions about scheduling and disposition of permanent records, such as
the regulation at 36 CFR 1234 and the Appraisal Guidelines for Permanent
Records, now published as an appendix in NARA?s Disposition of Federal
Records handbook. The second major change in 1988 was the GRS 23 treatment
of records

generated on personal computers. Like the 1988 GRS 20, the 1988 GRS 23 was
explicitly limited to disposable records: ?The records covered by this
schedule relate to routine internal administrative and housekeeping

activities.? GRS 23 provided disposal authority for temporary administrative
records generated by end- user applications on stand- alone or networked
computers. This included word processing files, spreadsheets, and
administrative databases. In addition to authorizing the destruction of
administrative or housekeeping records when no longer needed, the 1988 GRS
23 authorized the deletion of electronic versions of records created after
they were printed to hard copy, unless the records were maintained only in
electronic form. If the electronic record was

maintained only in electronic form, it could be deleted only after the
expiration of the retention period authorized for the hard copy by the GRS
or a NARA- approved SF 115. As NARA subsequently stated, its acceptance of
paper recordkeeping for electronic records was based on the assessment that
even with the growing use of computers, ?agencies continued to maintain
records produced with office automation applications in

organized paper files, especially since end- user applications were not 73
GRS 20 (June 1988); GRS 23, Records Common to Most Offices within Agencies
(June 1988).

designed to classify, index, and maintain documents for their authorized
retention period ?? Thus, the revised GRS authorized deletion of word
processing and E- mail records after they had been copied to paper or
microform. 74 The 1988 revisions to GRS 20 and 23 were followed by the 1990
revision to NARA?s electronic records management regulation. 75 This
revision continued the purposes of the 1985 bulletins, but provided more
detailed mandates for ?procedures to manage electronic records, to provide
for the selection and maintenance of electronic storage media, and to follow
the legal requirements for the disposition of such records.? Agency

requirements under this still valid and largely unchanged regulation include
the following:

 develop and implement an agencywide electronic records management program;

 establish procedures for addressing records management requirements before
approving new electronic records systems or enhancements to existing
systems; and

 specify the location, manner, and media in which electronic records will
be maintained to meet operational and archival requirements, and maintain
inventories of electronic records systems. While NARA endeavored to create a
comprehensive electronic records management scheme through the combination
of affirmative guidance, such as the 1990 regulation, and the revised
general records schedules, the GRS 20 principle that paper printouts could
substitute for electronic records became the focus of controversy through a
lawsuit challenging the 1989 destruction of White House E- mail tapes. The
case, Armstrong v. Executive Office of the President, spanned several years
and involved multiple issues and court rulings. In a 1993 ruling in that
case, the U. S. Court of Appeals ruled that paper printouts of E- mail
messages were not adequate substitutes for electronic versions stored on
computer tapes

because they ?may omit fundamental pieces of information which are an
integral part of the original electronic records, such as the identity of
the 74 GRS 20 (August 1995). 75 Electronic Records Management, 55 FR 19216
(May 8, 1990).

sender and/ or recipient and the time of receipt.? 76 Thus, the court
rejected the government?s argument that ?electronic records are merely
?extra

copies? of the paper versions,? and concluded that ?since there are often
fundamental and meaningful differences in content between the paper and
electronic versions of these documents, the electronic versions do not lose
their status as records and must be managed and preserved in accordance

with the FRA.? Largely in response to the court?s findings, NARA revised GRS
20 in 1995. 77 First, as an organizational matter, it moved the electronic
records instructions from GRS 23 into GRS 20 in order to have a single
general schedule for all disposable electronic records. This resulted in
combining instructions for the broad format categories of word processing
files, electronic mail records, and electronic spreadsheets with those for
specific

functional categories of administrative records, such as backup files,
finding aids, and systems operations records. Second, as a substantive
matter, NARA now instructed agencies to ?identify records created using
office automation and to maintain them in a recordkeeping system that
preserves their content, structure, and context for their required period.?
According to the GRS,

?Only after the records have been properly preserved in a recordkeeping
system will agencies be authorized by GRS 20 to delete the versions on the
electronic mail and word processing systems. As indicated, most agencies
have no viable alternative at the present time but to use their current
paper files as their recordkeeping system. As the technology progresses,
however, agencies will be able to consider converting to electronic

recordkeeping systems for their records.? Thus, NARA stated in the 1995 GRS,
?Program records that have been transferred to the recordkeeping system will
not be affected by GRS 20.? However, because NARA accepted the use of paper
files as appropriate recordkeeping systems for electronic records, this
logic permitted the

disposal of electronic versions of records that required retention or
permanent preservation. Accordingly, while GRS 20 did not authorize the
destruction of program records, it did permit the destruction of electronic
copies of those records. 76 Armstrong v. Executive Office of the President,
1 F. 3d 1274 (Aug. 13, 1993).

77 GRS 20 (August 1995).

In 1997, a Federal District court, in Public Citizen v. John Carlin,
overturned the 1995 GRS 20, finding that it did not go far enough to direct
agencies to protect electronic records. 78 The court ruled that NARA should
not have treated electronic records as disposable simply because they could
be copied into another form:

?[ The] differences between electronic and paper records illustrate the fact
that the administrative, legal, research, and historical value of electronic
records is not always fully captured- indeed, is usually not captured- by
paper or microfiche copies. Electronic records therefore do not become
valueless duplicates or lose their character as ?program

records? once they have been printed on paper; rather, they retain features
unique to their medium.? The court also found that NARA failed to perform
its statutory duty to evaluate the value of records for disposal: ?By
categorically determining that electronic records possess no administrative,
legal, research or historical value beyond paper print- outs of the same
document or record, the Archivist has absolved both himself and the federal
agencies he is supposed to oversee of their statutory duties to evaluate
specific electronic

records as to their value.? In response to the district court ruling, NARA
established an Electronic Records Work Group to review the 1995 GRS 20 and
make recommendations for revisions. It also issued a number of pieces of
guidance to reflect the District Court?s ruling. 79

On August 6, 1999, the U. S. Court of Appeals for the D. C. Circuit upheld
NARA?s GRS 20, reversing the District Court decision that had overturned the
1995 GRS 20. 80 The Court of Appeals rejected the lower court?s reasoning
that NARA had authorized destruction of all types of word processing and E-
mail records without regard to content: ?GRS 20 does not authorize disposal
of electronic records per se; rather, such records may be

discarded only after they have been copied into an agency recordkeeping
system.? 78 Public Citizen v. John Carlin, 2 F. Supp. 2d 1 (D. D. C. 1997).
79 See, e. g., NARA, Disposition of Electronic Records, Bulletin 98- 02
(Mar. 10, 1998); U. S. General Accounting Office, National Archives:
Preserving Electronic Records in an Era of Rapidly Changing Technology, GAO/
GGD- 99- 94 (Washington, D. C.: July 1999).

80 Public Citizen v. John Carlin, 184 F. 3d 900 (D. C. Cir. 1999).

The court acknowledged that an electronic recordkeeping system would be
superior to a paper recordkeeping system, but it also agreed with NARA that
agencies should be free ?to maintain their recordkeeping systems in the form
most appropriate to the business of the agency.? Thus the court said,

?We agree with Public Citizen that electronic recordkeeping has advantages
over paper recordkeeping, but our duty as a reviewing court is to ask only
whether the Archivist?s policy choice is arbitrary or capricious; manifestly
it is not. All agencies by now, we presume, use personal computers to
generate electronic mail and word processing documents, but not all have
taken the next step of establishing electronic recordkeeping systems in
which to preserve those records. It may well be time for them do so, but
that is a question for the Congress or the Executive, not the Judiciary, to
decide.?

Finally, the court found that the 1995 GRS 20 met the Armstrong test of
requiring that electronic records be stored in a manner that captures all
relevant transmission data.

As a result of the Court of Appeals ruling, NARA instructed agencies to
again use the 1995 GRS 20 to dispose of temporary electronic records after
recordkeeping copies were filed in electronic, paper, or microform
recordkeeping systems. 81 NARA did say, however,

?We believe there may be better alternatives to GRS 20 for disposition
authority for electronic copies of program records and expect to develop
those alternatives as part of a comprehensive review of the policies and
procedures for scheduling and appraisal of records in all formats. The Court
decision provides the Government time to include electronic copies in this
overall review. Our review may result in significant changes in the

way that agencies schedule their records in the future. When we have
completed this review, we will promulgate new guidance.?

On October 10, 2001, NARA published a notice seeking public comment on a
petition for rulemaking filed by the Public Citizen Litigation Group (a
plaintiff in both Public Citizen v. John Carlin and Armstrong v. Executive
Office the President) requesting NARA to revise its electronic records

management regulations. 82 In this notice, NARA stated that it was currently

?evaluating alternatives to GRS 20 for disposition authority as part of a
comprehensive review of the policies and procedures for scheduling and 81
NARA Bulletin 2002- 2 (Dec. 27, 1999).

82 66 FR 51739 (Oct. 10, 2001).

appraisal of records in all formats.? As of May 2002, this review was
ongoing.

Agencies Are Managing Large Volumes of

Appendi x V I Important Electronic Records Agencies are facing the complex
challenge of managing electronic records and in some cases maintaining these
records on a long- term basis. For example, because of their particular
missions, NASA, the Patent and Trademark Office, Veterans Affairs (VA), and
the State Department must each electronically manage millions of electronic
records, either long- term or permanently. In some instances, the volumes of
electronic records that these agencies manage are far larger than the
volumes of permanent electronic records that NARA currently archives. The
experiences of these

agencies highlight electronic records management and the gaps in existing
guidance. National Aeronautics and

NASA is committed to the long- term preservation of massive volumes of Space
Administration electronic space science data and images of our solar system.
The observational data sets from NASA missions record the continually
changing aspects of our Earth and represent an asset that must be retained
in a findable, accessible, and usable state. The agency proposed to
permanently maintain these data within the agency in order to support future
science usage. Presently, NASA?s National Space Science Data Center archives
over 20 terabytes of digital space science data from past

and present NASA missions, of which 3 terabytes are currently electronically
accessible. In addition, the Hubble Space Telescope has created a data
archive of over 7 terabytes of images of our solar system,

and continues to archive an additional 3 to 5 gigabytes every day. Archiving
and ensuring data integrity of all these electronic records require periodic
data renewal cycles, involving migration from old to new media,
resourceintensive data reorganization and reformatting, or even recreation
of related software.

Because these records are of permanent value and NARA has no means to
archive them in any useful way, NASA retains custody of them. They
accordingly fall into an undefined category: they are permanent records that
NARA cannot archive. The current arrangement by which they are

maintained is not covered by NARA guidance. Nor is NASA?s archiving approach
covered by this guidance, which does not cover migration and archival
formats (other than flat ASCII files on tape), management of digital images,
or maintenance of electronic records in databases for extended periods of
time.

U. S. Patent and Trademark The Patent and Trademark Office manages and
indefinitely preserves

Office millions of digitized patents and trademarks. Patent examiners must
have

access to a complete collection of the history of U. S. patents in order to
research prior art before approving new patents. Recently, the office
replaced the examiners? collection of paper patents with EAST (Examiners
Automated Search Tool) and WEST (Web Examiner Search Tool), which are
complete electronic patent collections containing the full text of over 2.5
million U. S. patents and full images of over 6.5 million U. S. patents and

over 14. 5 million foreign patents. In addition, the Patent and Trademark
Office has digitized the text and images of over 2. 7 million trademark
applications and registration. The Patent and Trademark Office has been
using XML 83 to develop and implement systems to support the filing,
examination, publication, and archival storage of intellectual property
documents in electronic format.

The Patent and Trademark Office?s digitization program has highlighted an
issue that is not adequately addressed by NARA guidance: that is, when a
record exists in many versions (electronic, paper, microform, etc.), which
should be considered primary? Many of the patent files that have been
digitized were originally paper files, and it has been argued that
destroying

the original paper versions after digitization has led to or risked loss of
important information. 84 Just as converting an electronic original to paper
may lead to information loss, so may the reverse. NARA guidance does not
address this issue, leaving agencies at risk of losing information. 83
Extensible Markup Language (XML) is discussed further in appendix II. 84 The
potential problem of information lost during the conversion from paper to
electronic patents was identified in a recent Congressional hearing: when
searching electronic patent databases for prior art, patent searchers miss
relevant patents. As noted in testimony by an association representing
patent researchers, this is due to a unique problem related to how an
invention is described: ?in many, if not most, cases the invention is never
fully described

?in the words. ? The patent law requires only that the specification,
including the drawings, together be understandable and enabling to one of
ordinary skill in the art to make and use the invention. ?The words, ? in
many if not most cases, merely ?flesh out? what is shown in the

drawings and do not replicate ?in words? what is in the drawings, but are
ancillary thereto. Thus, in a patent database electronic search one is often
presented the additional problem of ?searching? for ?words? which were never
there to begin with.? -Testimony of James F. Cottone, President, National
Intellectual Property Researchers Association, Oversight Hearing on the U.
S. PTO of the Subcommittee on Courts and Intellectual Property of the House
Judiciary Committee (Thursday, Mar. 9, 2000) (http:// www. house. gov/
judiciary/ cottone. htm).

Department of Veterans VA must manage and preserve, for 75 years, millions
of electronic medical Affairs

and benefit records. An integral part of VA?s enrollment process for each
veteran applying for health benefits is the use of several Veterans Health
Information Systems and Technology Architecture (VISTA) databases to enter
and verify veteran eligibility information. This information must be

maintained in the system and accessible for the life of the veteran in order
to document entitlement to health care benefits, which VA has determined to
be a maximum period of 75 years. One enrollment database alone

contains information for 9 million veterans. VA patient enrollment records
present another instance of the confusion regarding scheduling requirements
for electronic records and for records in multiple versions. Although VA is
working toward a completely electronic

process, enrollment records are initiated on paper because of current legal
requirements for ink signatures. In general, however, VA does not schedule
electronic records when it has scheduled the paper version. It is NARA
policy, however, that electronic records must also be scheduled. According
to VA, another key challenge that it faces is ensuring the validity and
authenticity of electronic records, and it would like to see adequate
guidance and standards about electronic signatures from NARA so that all
government agencies are using the same approach.

Department of State State electronically preserves over 25 million
diplomatic cables and more than 400,000 digital images of correspondence of
the Secretary of State. The State Archiving System (SAS) is a repository for
over 25 million cables, from 1973 to the present, documenting the conduct of
U. S. foreign policy. The cables are managed electronically for 25 years
before they are due to be transferred to NARA. However, if the cable records
in SAS had been

transferred to NARA for archiving, they would no longer have been accessible
to users. NARA has responded to the State Department?s archiving and access
needs by developing a new system (Access to Archival Databases), which is
expected to be available in the summer of 2002. This system will allow

NARA to provide on- line access to archived State Department cables. When
the system is available, the cable records will be transferred to NARA for
archiving.

In addition, the Secretariat Tracking and Retrieval System (STARS) tracks
approximately 440,000 digital images of foreign policy memoranda and

correspondence of the Secretary of State from 1986 to the present. Both
STARS and SAS must not only preserve the records, but also maintain reliable
and rapid access to the image data. As technologies change, preserving and
providing access to the records present complex electronic records
management challenges.

The State Department?s records management office has sole responsibility for
maintaining SAS, and it has had to proceed with the long- term management
and preservation of the system records- periodically updating and migrating
all the images to reflect new technologies- without guidance from NARA. NARA
guidance does not address updating or

migration of file formats.

Comments from the National Archives and

Appendi x V Records Administration

Glossary administrative records Records created by several or all federal
agencies in performing common

facilitative functions that support the agency?s mission activities, but do
not directly document the performance of mission functions. Administrative
records relate to activities such as budget and finance, human resources,

equipment and supplies, facilities, public and congressional relations, and
contracting. Administrative records are temporary and are covered by general
record schedules.

business process A collection of related, structured activities- a chain of
events- that produce a specific service or product for a particular customer
or customers. data architecture The framework for organizing and defining
the interrelationships of data in

support of an organization?s missions, functions, goals, objectives, and
strategies. Data architectures provide the basis for the incremental,
ordered design and development of systems or subject databases based on
successively more detailed levels of data modeling.

electronic record In the context of the federal government, any information
that is recorded by or in a format that only a computer can process and
satisfies the definition of a federal record in 44 U. S. C. 3301.

electronic recordkeeping system An electronic system in which records are
collected, organized, and categorized to facilitate their preservation,
retrieval, use, and disposition.

enterprise architecture An institutional systems blueprint that defines in
both business and technology terms an organization?s current and target
operating environments and provides a road map for moving between the two.
Extensible Markup Language

A flexible, nonproprietary set of standards for tagging information so that
it (XML) can be transmitted using Internet protocols and readily interpreted
by disparate computer systems.

federal records In the context of federal recordkeeping, all books, papers,
maps, photographs, machine- readable materials, or other documentary
materials, regardless of physical form or characteristics, made or received
by an

agency of the U. S. government under federal law or in connection with the
transaction of public business, and preserved or appropriate for
preservation by that agency or its legitimate successor as evidence of the
organization, functions, policies, decisions, procedures, operations, or

other activities of the government or because of the informational value of
the data in them. metadata Data containing descriptive information about
other data. office automation records Electronic records created by means of
office automation software, such

as word processors, spreadsheets, other desktop applications, or electronic
mail. office automation The techniques and means used for the automation of
office activities, in

particular, the processing and communication of text, images, and voice.
permanent records Records that NARA appraises as having sufficient value to
warrant

continued preservation by the federal government as part of the National
Archives of the United States.

Portable Document Format A proprietary de facto standard for electronic
document distribution

(PDF) worldwide. Created by Adobe Systems, the portable document file format
preserves all the fonts, formatting, graphics, and color of any source

document, regardless of the application and platform used to create it.
program records Records created by each federal agency in performing the
unique functions that stem from the distinctive mission of the agency. The
agency?s mission

is defined in enabling legislation and further delineated in formal
regulations. Program records may be temporary or permanent; they must be
scheduled. record See federal records.

recordkeeping system A manual or automated system in which records are
collected, organized, and categorized to facilitate their preservation,
retrieval, use, and disposition.

recordkeeping The act or process of creating and maintaining records.
records management The planning, controlling, directing, organizing,
training, promoting, and

other managerial activities involved in records creation, maintenance and
use, and disposition in order to achieve adequate and proper documentation
of the policies and transactions of the federal government.

records management application The term used by the Department of Defense?s
Design Criteria Standard for Electronic Records Management Software
Applications (DOD 5015.2- STD) for software that manages records. The
primary management functions of such software are categorizing and locating
records and identifying records that are due for disposition.

records schedule A document providing mandatory instructions for what to do
with records no longer needed for current business, with provision of
authority for the final disposition of recurring and nonrecurring records.

technical reference model A taxonomy that provides a consistent set of
service areas, interface categories, and relationships to address
interoperability and open systems; part of an enterprise architecture.

temporary records Records appraised as having temporary or limited value and
approved for destruction either immediately or after a specific period of
time.

Usenet An Internet- based worldwide distributed discussion system. Usenet
consists of a set of ?newsgroups? with names that are classified
hierarchically by subject. ?Articles? or ?messages? are ?posted? to these
newsgroups by people on computers with the appropriate software; these
articles are then broadcast to other interconnected computer systems via a

wide variety of networks. XML See Extensible Markup Language.

XML document A text document marked up with hierarchically arranged
descriptive tags and attributes conforming to the XML standard. An XML
document can also begin with declarations that refer to other files
providing further instructions for interpreting and displaying data
elements.

(310323)

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a

GAO United States General Accounting Office

Why GAO Did This Study

In the wake of the transition from paper- based to electronic processes,
federal agencies are producing vast and rapidly growing volumes of
electronic records. The difficulties of managing, preserving, and providing
access to these records represent challenges for the National Archives and
Records Administration (NARA) as the nation?s recordkeeper and archivist.
GAO was requested to (1) determine the status and adequacy of NARA?s
response to these challenges and (2) review NARA?s efforts to acquire an
advanced electronic records archiving system, which will be based on new
technologies that are still the subject of research.

June 2002 INFORMATION MANAGEMENT Challenges in Managing and Preserving
Electronic Records

This is a test for developing highlights for a GAO report. The full report,
including GAO?s objectives, scope, methodology, and analysis is available at
www. gao. gov/ cgi- bin/ getrpt? GAO- 02- 586. For additional information
about the report, contact Linda Koontz, 202- 512- 6240. To provide comments
on this test highlights, contact Keith Fultz (202- 512- 3200) or email
HighlightsTest@ gao. gov.

Highlights of GAO- 02- 586, a report to Congressional Requesters

What GAO Recommends

GAO recommends that the Archivist of the United States develop documented
strategies to raise awareness of the importance of records management
programs and for conducting systematic inspections of these programs. In
addition, to reduce risks, GAO recommends that the Archivist reassess the
schedule for acquiring the new archival system so that the agency can
complete key planning tasks and address IT management weaknesses. In
commenting on a draft of this report, the Archivist agreed with our
recommendations and offered clarifications, which we have incorporated as
appropriate.

United States General Accounting Office

What GAO Found

NARA has taken action to respond to the challenges associated with managing
and preserving electronic records. In 2001, NARA completed an assessment of
the current federal recordkeeping environment. This study concluded that
although agencies are creating and maintaining records appropriately, most
electronic records (including databases of major federal information
systems) remain unscheduled (that is, their value has not been assessed nor
their disposition determined), and records of historical value are not being
identified and provided to NARA for archiving. As a result, valuable
electronic records may be at risk of loss. Part of the problem is that
records management guidance is inadequate in the current technological
environment of decentralized systems producing large volumes of complex
records. Another factor is the low priority often given to records
management programs and the lack of technology tools to manage electronic
records. Finally, NARA does not perform systemic inspections of agency
records management, and so it does not have comprehensive information on
implementation issues and areas where guidance needs strengthening. Although
NARA plans to improve its guidance and address technology issues, its plans
do not address the low priority generally given to records management
programs nor the inspection issue.

Recognizing the limitations of its technical strategies to support
preservation, management, and sustained access to electronic records, NARA
is planning to design, acquire, and manage an advanced electronic records
archive; however, this project faces substantial risks. Although the
electronic records archive project is in its initial stages, it is already
falling behind schedule. Further, to acquire a major system of this kind,
NARA needs to improve its information technology (IT) management
capabilities, and although it has made progress in doing so, its efforts are
not yet complete.

Master Copies of Electronic Records in NARA?s Archives Source: NARA.

G A O Accountability Integrity Reliability

Highlights

Page i GAO- 02- 586 Information Management

Contents

Contents

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Appendix I

Appendix I Objectives, Scope, and Methodology

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Appendix II

Appendix II Approaches to Archiving Electronic Records Provide Partial
Solutions

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Appendix II Approaches to Archiving Electronic Records Provide Partial
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Appendix II Approaches to Archiving Electronic Records Provide Partial
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Appendix II Approaches to Archiving Electronic Records Provide Partial
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Appendix III

Appendix III NARA?s Electronic Records Guidance Has Evolved

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Appendix III NARA?s Electronic Records Guidance Has Evolved

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Appendix III NARA?s Electronic Records Guidance Has Evolved

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Appendix III NARA?s Electronic Records Guidance Has Evolved

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Appendix IV

Appendix IV Agencies Are Managing Large Volumes of Important Electronic
Records

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Appendix IV Agencies Are Managing Large Volumes of Important Electronic
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Appendix V

Appendix V Comments from the National Archives and Records Administration

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Appendix V Comments from the National Archives and Records Administration

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