Date: Tue, 28 Jan 1992 14:20:09 EST
From: James P Love <[email protected]>
Subject: File 6--PRA/Owens Bill (response to EFF response)

++++++++++++++++++++++++++++Original message++++++++++++++++++++++++++++

January 27, 1992

Jerry Berman
Director, Washington Office,
 EFF
666 Pennsylvania Avenue, SE
Suite 303
Washington, DC 20003

RE:  PRA/Owens Bill

Dear Jerry:

Here are my suggestions regarding the principles that should
prevail in a PRA (and/or) Owens bill.

1.   Agencies should have an unambiguous mandate to provide
    access to federal information in a variety of formats and
    modes.  The agencies should make reasonable efforts to
    respond to requests for access to data stored in electronic
    formats.  This should include requests that data be
    disseminated in ways that make it convenient to receive and
    use (i.e. floppy disks, CD-ROMs, standardized record
    structures).

2.   Agencies should have a clear mandate to provide online
    access to government information, and to use computer
    networks, such as the Internet, for dissemination.

3.   Agencies should provide information products and services to
    the federal depository library program.

4.   The agency should provide access to underlying records of
    databases, as well as to value added services, including
    those that are developed for use by government employees.

5.   The agency's mandate to disseminate information should not
    evaporate simply because there are private sector
    alternatives.  (i.e. the PRA "check list").

6.   The government should charge no more than the incremental
    cost of dissemination for information products _and_
    services.

7.   Agencies should be encouraged to embrace standards for such
    things as record formats and query commands.

8.   The public should have frequent and regular opportunities to
    review agency policies and practices and offer criticisms.
    Agencies should be required to say what they have done about
    those criticisms.

9.   The legislation should not enhance OMB's role in setting
    federal information policy.  11 years of ORIA work in this
    area should be enough to convince anyone that OMB is a
    terrible choice for this role.

10.  The legislation should not become embroiled with battles
    over OMB's powers to review federal regulations or the
    federal government's authority to require firms to post
    health and safety notices.  These are important issues, but
    when the legislation embraces these issues no one pays any
    attention to the information dissemination issues.  Federal
    information policy is too important to be decided in an
    environment where every move is determined by players who do
    not care or know about information policy issues.

In my mind, the Owens bill addresses these issues better than the
PRA.  Perhaps it is possible to incorporate features of the Owens
Bill in the PRA legislation, while avoiding the negative baggage
that the Paperwork Reduction Act carries with it.  I'm not
convinced, but I have an open mind.

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