Defense Media Activity Response to NARA Strategic Plan

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DVI Response to NARA Draft 2018 Strategic Plan v3.docx

Defense Media Activity Response to NARA Draft 2018 Strategic Plan

• Maximize NARA’s Value to the Nation, Initiative #2: “By December 31, 2022, NARA will no longer accept transfers of permanent or temporary records in analog formats and will accept records only in electronic format and with appropriate metadata.”
NARA PARTNER/STAKEHOLDER FEEDBACK: As the designated Department of Defense (DoD) central manager for all unclassified special media records, the Defense Media Activity (DMA) hereby provides feedback on the NARA draft 2018 Strategic Plan. Under the authorities established by DoD policy and the DoD VI Records Schedule, this feedback is the official response on behalf of the Office of the Secretary of Defense, the Military Services, and the Defense Agencies with regard to special media collections.
SUMMARY STATEMENT: The Department of Defense critically non-concurs with NARA’s proposed elimination of analog/physical record transfers to NARA by 2022.
RATIONALE: The proposed change;

1. Increases risk of losing or alienating physical special media records due to short timeline. The designated DoD central special media records center, the Defense Imagery Management Operations Center (DIMOC), currently has 3.1 million analog special media records. DIMOC is implementing a ten-year plan for outreach across the Department to collect all the remaining physical special media records. This program has already resulted in an analog media growth of 800K records and is projected to grow by another 4 million by 2022.
   Our clients across the Department tell us the transfer of their analog media records to DIMOC is dependent on their ultimate transfer to NARA for preservation. If NARA stops accepting these master records from DIMOC, our clients will be inclined to keep their media rather than transfer it. Ultimately, this will result in the alienation of federal records due to the declining ability to playback, preserve, and digitize legacy analog media.

2. Shifts the burden and associated costs from NARA to DoD
   Eliminating the transfer of physical special media to NARA increases the internal cost to DoD for preservation of master analog media records, additional destruction and workflow procedures, and additional shipping costs to return physical records to the originating clients. DoD estimates the following additional costs must be absorbed by the agency if NARA will no longer accept analog/physical special media records by 2022:
   o $30 million to digitize the 3.1 million on-hand analog media records at DIMOC
   o $36 million to digitize future incoming physical media records (2018-2027)
   o $1.3 million annual additional cost to store and manage analog/physical special media records starting in 2023
   o $110,000 for additional analog record destruction and shipping costs (2023-2027)
    

3. Negatively impacts the Department’s authorities and workflows for the collection of and management of Special Media Records.
   Effective workflow within DoD relies on the authority established by the DoD Visual Information Schedule (DAA-0330-2013-0014) and Department policy for all permanent special media records to be sent to the Defense Imagery Management Operations Center; who ultimately accessions them to NARA. Compliance with this policy strongly depends on the promise that master analog media records will be transferred from DIMOC to NARA for preservation. The elimination of the longstanding physical record mandate by 2022 undermines DIMOC’s Department-level authority and the established centralized workflow. Under the proposed NARA change many DoD components would rather hold onto their master analog media records rather than send them to DIMOC where they may be destroyed.
   BACKGROUND: As a Federal Agency, the Defense Department maintains a designated audiovisual records center and central media collection point in order to (a) promote efficiency and reduce overall storage and processing costs; (b) increase the value of special media as a strategic information resource through centralized access, and (c) ensure the preservation of the visual history of the United States. Eliminating physical record transfers to NARA by 2022 undercuts the authority of this process and would seriously diminish the essential functions and mission of the DIMOC.

Julia Hickey
Archivist
Defense Media Activity (DMA)
Defense Imagery Management Operations Center (DIMOC)
6700 Taylor Ave
Ft Meade MD 20755
301.222.6525
julia.s.hickey.civ@mail.mil