Dear Editor,

I wish to comment upon Professor Ron Formisano's letter in the September 1989 issue of Perspectives. In commenting, I want mainly to present a record of the developmental work leading to the legislative proposal and the deliberations that took place at the table of the National Historical Publications and Records Commission. I do not wish to appraise the merits of the balance of representation around the Council table.

When we knew that a reauthorization of the Commission's grant program would have to be in place by September 30, 1988, Richard Jacobs, then acting executive director, reported to the Commission at its October 1986 meeting that he had begun working on a revision of an earlier draft that would make certain technical amendments to the underlying legislation as well as reauthorize funding for the grant program. At the February 1987 meeting Jacobs distributed copies of the draft to the Commission members, explained the proposed changes, and requested a resolution from the Commission as to the appropriate level of funding to seek. The resulting resolution called for $10 million for each of five years.

In April 1987, as Acting Archivist (and Chair of the Commission) I forwarded the draft and a legislative proposal to the Office of Management and Budget (OMB) for submission to the Congress. Some months later, OMB notified me that I was authorized to forward the technical amendments to Congress provided I strip out any reference to reauthorization of the grant program. I acted accordingly and in July 1987 forwarded the technical amendments to Congress. The two Congressional members serving on the Commission were, of course, aware of the Commission's ruling calling for $10 million in annual funding.

During the development of the legislative proposal, it had come to the Commission's attention that several outside professional groups sought to be named members of the Commission. While the proposal that had been drafted contained changes in the method and timing of appointment of members, it did not propose any other difference in membership or constituency. Richard Jacobs and I agreed that no such changes should be undertaken without prior discussion with the Commission members. We therefore placed on the agenda for the June 1987 meeting a further discussion of the reauthorization proposal, having in mind specifically to discuss with Commission members the prospect of changes in membership. That discussion took place and is reflected in two-and-a-half pages of minutes of the Commission meeting. Dr. Formisano was absent from the two-day Commission meeting at which the topic was discussed, but was sent a copy of the minutes. The discussion included consideration of additional organizations, an observation of the prospect that membership might be reduced to one representative per organization, and a consensus conclusion that a sitting Commission should not decide upon its own increase or reduction, which is properly a matter for the legislature to determine after the concerned organizations let the Congress know their stand on the issue.

In the final stages of preparation of the legislation, Jacobs had a discussion with congressional committee staff in which he was informed that a number of organizations (variously cited as 2, 3, and even 4) were actively seeking membership. When he was asked his opinion on the matter, Jacobs noted the Commission discussion the preceding June, commented that the organizations named all had suitable interests in the Commission's programs, and stated that my position, as Archivist/Chair, was that, should additional organizations be added to the membership roster, representation should be reduced to a single member from each organization for reasons of economy and manageability.

The legislation passed on July 1988, and by far the most important result for the Commission was reauthorization of the grant program for five years at increased levels annually, reaching $10 million by 1993. In addition, action by the House committee resulted in adding representation for the Association for Documentary Editing and the National Association of Government Archives and Records Administrators, and reducing representation of all organizations to one member each.

Congressional staff had told me in conversations that their goal was to reduce the Commission size under any circumstances. They proposed elimination of the representatives from the Departments of State and Defense, as well as the Library of Congress. I objected on grounds that these were three representatives who could have no conflict of interest, since their agencies could not receive grant funds under the proposed legislation. In addition, as historians (and all, presumably, members of the AHA) they knew intimately the value of many of the documents, secretaries of state, military officers, congress members, and, indeed, the records of the First Federal Congress. I also felt that it was not politic for me to say that I would prefer having representatives of one group on the Commission over those of another, and that the groups should make their own case to the Congress and let it decide.

I was no longer with the Archives when the question was again raised at the October 1988 meeting of the Commission, but I understand that Jacobs was present as an observer and volunteered a comment to the Commission which is substantially what is reported in this letter. I would think that Dr. Formisano would have copies of the minutes of the two meetings reported on.

In my view, the issue of representation on the Commission was properly aired at the Commission table and appropriately resolved by the legislative process in the American political tradition. Only time and the new Commission's deliberative record will tell whether it can function effectively under its revised constituency.

Frank G. Burke
Former Acting Archivist of the United States and Professor
Department of Library and Informational Services
University of Maryland, College Park