The U.S. Department of Education has caused a stir among educators, researchers, public interest groups, and libraries and information access/service providers with its decision to remove and deleter files from its websites, highlighting a conflicting set of interests buffeting federal agencies with respect to their online information. At risk are not only an extensive amount of news, information, and resources used by students, parents, teachers, and researchers, but also a vast amount of research and papers, a number of which provide commentary and counterpoint to past and present administrations' education goals, initiatives, and program performance. Also on the chopping block is a substantial amount of information contained in the information digests published through the Educational Resources Information Center (ERIC), a national information system created in 1966 with Department of Education support to provide access to education-related literature through a network of 16 subject-specific clearinghouses and a range of support entities. ERIC also encompasses a range of research tools, including print and electronic directories, journals, and information referral services, and the digests provide an easy-to-read indicator on current topics and resources across a wide range of education related subjects. The Education Department states, according to Michelle Davis's 9/18/02 Education Week account, that the deletions are only of old, outdated files which are no longer recording any online traffic or being linked to by outside sources, in an effort to make information more usable and accessible and as relevant as possible to the present administration's goals. The activity is a part of the department's fourth comprehensive website redesign since the original site launched in 1993. The current site draws over 84,000 daily visits and contains over 50,000 files. Davis's article also notes that the department's assistant secretaries were given, around late May 2002, a list of files under consideration for deletion-- encompassing nearly every file prior to February 2001, unless it is legally required or directly supports the main initiatives or key education goals of the Bush administration. What is not clear, however, is why information is not simply being archived as opposed to being deleted; how knowledgeable staffers are with respect to offline and online but non-public or non-web information sources that may currently be linking to existing information; and who ultimately makes the final cut for information, information technology staffers, program staff, agency managers, or department leadership, and if those decisions are being made with public user input. Valid Concerns Federal agencies have been reevaluating what should and shouldn't be publicly available, in the wake of heightened concerns around lack of information coordination following September 11, 2001. By October 2001, some federal government websites-- including the Centers for Disease Control, Environmental Protection Agency, Nuclear Regulatory Commission, and Transportation Department-- went so far as to remove from public view any and all information considered useful to terrorists. In actuality, information was pulled wholesale, without an intermediate process of prioritization and review with regards to actual risk. By March 2002, the White House ordered an across-the-board "web scrub" of information to be removed from federal agency websites that might aid terrorists in the preparation or use of weapons of mass destruction, due in part to revelations that there was information online even agencies themselves were not aware existed. The risk included unclassified yet potentially damaging information, like chemical manufacturing facility maps. At the time, the Information Security Oversight Office (housed under the National Archives & Records Administration, the federal government's chief record keeper), and the Department of Justice's Office of Information & Privacy, in a 3/19/02 memorandum had also directed agencies to take care in declassifying documents, even those already slated to be declassified; to classify (and in some instances reclassify) already declassified information or previously unclassified information; and to carefully review information considered "sensitive" while carefully assessing reasons for not disclosing it if requested, regardless of classification status. This move created a significant outcry that the government was moving away from maintaining the public's right to know on information access towards a need to know basis. Rembrances of Files Past Ironically, while there were efforts to pull information offline, and a new category for government information proposed around "sensitive but unclassified" information whose determination would rest in the hands of individual agency managers, NARA acknowledged that it was drowning in electronic information and records, its ability to keep up with the deluge severely undermined by antiquated and inconsistent technology, and information standards based on printed materials. Practically speaking, there is only so much physical space that can accommodate volumes of printed information, which can require a lot in terms of money and people and labor to preserve them. Ideally, an electronic or online archive could handle agency overflow-- especially when it is hard to determine at what point an infrequently accessed document becomes useful, in the context of a rulemaking or legal proceeding or administrative review. Electronic information, however, raises difficulties for agencies, because if they are treated as records, as opposed to merely files, the manner in which they must be preserved is different by their very nature. The discussion as to which electronic files should be treated as records, while raising many technical and procedural issues, is an important one. In general, documents determined by agencies to be of a priority and importance meriting archiving, must have their value appraised according to criteria issued by NARA to determine whether they will be archived as records on a temporary or permanent basis. There is not, however, a clear set of enforceable standards or enforced guidelines with respect to electronic documents and their treatment as records. Web pages, for example, may have specific requirments in terms of when and how they are created and update according to specific agency standards. As such, they may undergo many changes in design or content in any given period of time. Which version and how often should a page be catalogued and archived, and which would present an accurate "record" of the information contained therein? An individual e-mail message raises even more difficulty. It could be considered a discrete piece of information, or a part of a chronological or topical collection of information. A recipient may opt, when reading a message, to group it with other messages or place it in a special archive. That same recipient may make print out a paper copy of that e-mail message, which may or may not contain written notes in the margin. That original e-mail message, moreover, might have been sent or forwarded to other recipients whose e-mail addresses may or may not be visible, along with a message that may or may not have contained attachment files. Lastly, that message may, when received electronically or printed out, contain all manner of formatting or technical information in the message header, which might not be captured as the message form changes. All this means that a great deal of electronic information rests at the mercy of information technology personnel or agency staff who may not be able to recognize the value of current and past electronic files and documents from the standpoint of a record that may gain value or importance as a snapshot of agency activity over time or within a fixed time period. The Record To Date When attempts have been made across agencies to at least begin addressing inconsistencies and inadequacies in electronic record preservation and access for web pages and PDF files, there have been coordination problems. That is because each agency currently sets its own rules in terms of what to keep and what to discard, and under what circumstances such determinations are made. This makes the process for determining how to collect and catalog which information in what format difficult one. Even efforts like FirstGov only go so far towards coordinating with existing agency standards for online information sources and websites. Consider the confusion that erupted around spring 2001, during the rush to compliance with Section 508 accessibility standards. One incident, reported in the 4/16/01 edition of Civic.com involved website managers at the General Services Administration, who interpreted an internal memorandum sent by another agency manager to delete any Internet files that did not meet the standards, at the risk of having their entire sites yanked offline. The memorandum had, instead, reportedly suggested that only old or totally unused files were to be deleted, while new and existing content was to be moved or consolidated onto new and accessible sites. Where the memo had not been supposedly clear was on the need to backup or copy the old files for archival purposes or later use by the public. In July 2002, NARA was prompted to begin an effort that would at least clarify what many considered too amorphous an approach to preserving electronic records. Under the proposed plan agencies would be given advice on what types of records to keep, but not how to keep them. NARA would expand the range of documents it accepts, conduct periodic records assessment and evaluation, and share expertise on broad record management solutions. While hailed by some as an attempt to finally clarify some much-needed guidelines, the plan was simultaneously attacked as an attempt by NARA to shirk its leadership responsibility to guide agencies through these difficult issues. Concern was raised especially with respect to the suggestion to change the schedules for how long certain types of information would be kept, exposing other records to potential removal or deletion in the process. The public demands that more information, including older and specialized files, be made available online in an accessible and usable manner. Government agencies are also asked to demonstrate, by the department and executive branch under which they operate, that they are doing their work efficiently and effectively. The Education Department's actions, however, sends the message that anything put online prior to the current administration is without value, and should therefore be discarded, the complete opposite of the spirit under which the website was first launched by the Clinton administration in 1993. The current Education Department approach suggests that the determination of usefulness and value of any older information is to be made by current staffers who may not use the information on a regular enough basis to make informed decisions, who must then plead with an assistant secretary if a case can be made for keeping that information. A cross-section group of Education Department agency administrators reviewed the existing 50,000 online files and electronic documents without direct input from the public-- except through website traffic statistics and measures of interest like information requests. Files that are no longer linked to by other web-based sources, according to any Education Department agency, are fair game as well, but the overlooked fact is that orphans may very well result by the reshuffling of information currently taking place. Any outside sources not brought to the agency's attention would find itself containing information that could not be verified or certified as current or accurate, or might find itself with a number of broken links. That following through on both public and government interests would mean presenting only information that makes an administration look good is curious if not potentially bothersome, for it presents a narrow, distorted view of how government works as much as what government does. It sends the message that the public has no say in the work it pays for. That some information is being not only removed, but deleted, and without any apparent regard to what is useful now and may be necessary at a later date, is worrisome. That such activity is done in the name of usability and accessibility without public weighing or input is a troubling, unnecessary pitting of one set of interest against another.