Date: Tue, 28 Jan 1992 14:20:09 EST
From: James P Love <LOVE@PUCC.BITNET>
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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