Open Government Directive: Another ambiguous, unfunded, and edental mandate?
Before you send me hate mail let me state that I am all for Federal agencies sharing data in the sprit of open government, but we have to do it smart way, making sure that:
- We fully understand why we want it and are clear about what we are really asking for;
- We understand the burden involved in achieving open government and that we fund the agencies to do it right;
- We are clear about the performance questions that we want the [transparent] data to answer;
- We have an understanding for how the public will want to see/access the information; and
- We are fully prepared to digest and respond to received public feedback .
After reading the 3,185 words of the Office of Management and Budget (OMB) Open Government Directive (with attachment), I am very sorry to report that IMO none of the five critiera (conditions) listed above have been met by the language contained in the document. From what I read:
- It would appear that no one in the approval chain asked any hard questions about the language–much of the language used is very vague and leaves a lot of room for interpretation (or misinterpretation);
- There is no mention of how agencies will be funded to build the capacity to meet the additional workload that the requirements of the memorandum are certain to cause.
- The focus of the document to “get agency data on the web” and “solicit (direct) public feedback” appears to be totally out of context of any other strategic management, performance assessment, or planning framework. This appears to ba an end-run around other oversight committees and organizations, like Congress. Will Federal agencies be able to deal with direct feedback from hundreds or thousands of citizens? I am reminded of the old adage “be careful what you ask for”…;
- The document tells agencies to “publish information online in an open format that can be retrieved, downloaded, indexed, and searched by commonly used web search applications;” however, this can be satisfied in many ways–.txt, .csv, .doc, .pdf, .html,.xml, etc.–some formats will make it very cumbersome for the “public” to view, analyze and understand the data.
- Finally, the memorandum sets what I believe to be some very unrealistic expectations from both a performance and timeline perspective. For example, how can agencies be expected to review and respond to public input from the web when these same agencies are already overwhelmed with their current day-to-day tasks?
Here are a couple examples to ponder:
On Page 2 – “To increase accountability, promote informed participation by the public, and create economic opportunity, each agency shall take prompt steps to expand access to information by making it available online in open formats”
- Nowhere in the memorandum are the terms “accountability” or “informed participation” defined
- What does “create economic opportunity” really mean?
- It would appear that this mandate circumvents established management processes for holding Federal agencies accountable for efficient and effective performance? (OMB,GAO, Congress)
On Page 3 – “Each agency shall respond to public input received on its Open Government Webpage on a regular basis…Each agency with a significant pending backlog of outstanding Freedom of Information requests shall take steps to reduce any such backlog by ten percent each year.”
- What do the mean by “respond to public feedback on a regular basis?”
- All feedback? Some feedback?
- What does “regular basis” mean? Within 24 hours? Weekly? Annually?
If we really want Federal agencies to be more “open” with their data and information, we must be willing to commit the effort required to:
What are your thoughts and comments on this issue?
Thanks…r/Chuck
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