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On December 30, 2019 ART submitted comments in opposition of the proposed changes to the fees for accessing the historic public records of the United States Citizenship and Immigration Service (USCIS). The changes outlined in the agency’s proposed rule under Department of Homeland Security (DHS) Docket No. USCIS-2019-0010 sought to significantly increase the fee for the agency to search the Master Index of the Genealogy Program from $65 to $240 (increase of 269%) and increase the fee to get reproductions of records from $65 to $385 (increase of 492%). ART opposes these exorbitant fees increases, just two among many fees increases proposed by the USCIS, and also urges the USCIS to transfer its historic records to the National Archives and Records Administration (NARA), where the records would be managed more efficiently, accessed more freely, and reproduced more economically. ART_statement_USCIS_fees_increase_20191230.docx
In November 2019 ART signed on to a letter urging Thomson Reuters (owners of Westlaw) and RELX (owners of Lexis-Nexis) to cancel their contracts with Immigration and Customs Enforcement. In this effort, part of a larger campaign to get tech and data companies to stop doing business with ICE, ART joined a group of community organizations, law professors, law students, librarians, and practicing attorneys.
On November 19, 2019 ART submitted a letter to Yale University regarding its decision to cease providing funding to the Native Northeast Research Collaborative. The Native Northeast Research Collaborative has been a part of the Yale community since 2003, beginning as a scholarly editing project initiated by the chairs of the History Department and the American Studies Program. In its sixteen years of existence, it has achieved much, from making thousands of primary source documents available through its Portal, to its intensive work with the content management system Mukurtu, created by and with indigenous communities to manage their digital cultural heritage, to its creative and wide-ranging educational outreach initiatives and its Native Partners and Native Internship Programs. ART_letter_Yale_NNRC_20191118.docx
On August 5, 2019 ART submitted comments on the revised, proposed records retention schedule of the Department of Homeland Security, Immigration and Customs Enforcement (ICE), Detainee Records DAA-0567-2015-0013. This was the third submission of comments from ART (previously in 2017 and 2018) regarding the records retention schedule of ICE Detainee Records. ART_ICE_rrs_comments_20190805.pdf
On May 1, ART signed a coalition letter (issued by the Center for Democracy & Technology (CDT)) to United States Department of Homeland Security (DHS) and United States Customs and Border Protection (CBP) urging the agencies to cease targeting activists, journalists, and lawyers based on their First Amendment-protected speech and associational activities near the Mexico–United States border. This surveillance violates the Privacy Act of 1974, which states that a government agency cannot create records of U.S. citizens and lawful permanent residents’ First Amendment activities when they are not pertinent to and within the scope of its authorized law enforcement activity. Both agencies responded with individual letters--DHS issued a standard reply, while CBP confirmed suspicion of activists as a means to justify increased surveillance, in its own letter.
Today, ART joined a coalition of over 100 organizations in sending a letter to the U.S. Department of Homeland Security (DHS) urging it to cease any targeting of activists, journalists, and lawyers based on their First Amendment-protected speech and associational activities. The coalition urges DHS to address alarming reports of surveillance activity by U.S. Customs and Border Protection (CBP) and U.S. Immigration and Customs Enforcement (ICE) that jeopardizes First Amendment rights and access to legal counsel, and may violate the Privacy Act of 1974, which states that a government agency cannot create records of U.S. citizens and lawful permanent residents’ First Amendment activities when they are not pertinent to and within the scope of its authorized law enforcement activity.
ART has issued a statement opposing the U.S. Department of the Interior (DOI) Request for Records Disposition Authority (DAA-0048-2015-0003) and the National Archives and Records Administration (NARA) records appraisal, which identify for destruction (going back 50 years as well as date forward) records from every agency within the DOI, including the Bureau of Land Management, National Park Service, U.S. Fish & Wildlife Service, U.S. Geological Survey, Bureau of Safety and Environmental Enforcement, Bureau of Indian Affairs, and others. These records touch on a range of subjects including oil and gas leases, mining, dams, wells,timber sales, marine conservation, fishing, endangered species, non-endangered species, critical habitats, and land acquisition.
We urge NARA to gather public input, including the input of specialists in these fields, about the long-term importance of these records, and we ask them to consider other methods of retention, such as keeping the records in an electronic format.
In addition, we strongly recommend that NARA deny the proposed change of “disposition authority” from individual bureaus to the office of the Secretary of Interior, a cabinet-level political appointee, which could overly politicize records retention across the entire agency going forward.
Read the full statement here.
ART has issued a statement to the New York City (NYC) Charter Revision Commission affirming our hope that the 2019 Charter mandates the Commissioners and heads of the NYC Department of Records and Information Services (DORIS) be trained archivists, librarians, and/or records managers, holding the degrees of MLIS and/or MA in Archives and Records Management. As archivists, librarians, records managers, and related information professionals, we are required to hold graduate-level degrees, and we strongly believe that the heads of DORIS need to have this level of education to be able to effectively carry out their duties. The Commissioner and Assistant Commissioner should also be professional archivists, librarians, or records managers holding the education and experience defined in the City Charter, and not political appointees. Read the full letter here.
Last October, ART wrote a letter to the National Archives and Records Administration (NARA) opposing the destruction of 11 types of records relating to abuses of detained individuals in U.S. Immigration and Customs Enforcement (ICE) custody, including documentation of deaths and sexual assaults.
The Library Journal mentioned these efforts in a recent article describing the overwhelming opposition to the proposed retention schedule, as well as NARA's plans to open a 15-day public comments period on the revised ICE retention schedule via the Federal Register.
ART has joined 24 other organizations in opposing the Bureau of Justice Statistics’ (BJS) proposal to collect citizenship and country of birth information about state and local prisoners, a data collection project of dubious efficacy and accuracy.
Read the full letter here.