April 8, 2014

Mr. David S. Ferriero
Archivist of the United States
National Archives and Records Administration
700 Pennsylvania Avenue, NW
Washington, DC 20408

Dear Mr. Ferriero:

The American Historical Association takes note of NARA’s proposed draft guidelines that require NHPRC grantees to “publish online editions and provide free online access.” We agree that broad dissemination of these essential documents is imperative, and hence support the requirement that grant proposals to NHPRC include plans for digital publication. We are less certain that either historical scholarship or public culture is well served by a rigid requirement that such dissemination be free of charge.

NHPRC funding has encouraged and supported the valuable and painstaking documentary editing work that has made collections of carefully edited primary sources available to historians, educators, and the public. The publications are of inestimable value to the nation and support the public culture and citizenship that is vital for sustaining democracy. The AHA is pleased to see proposed changes that will even further broaden the presence of these documents in American public culture, but it is equally imperative to maintain the quality of historical scholarship that is essential to the utility of these materials.

The collections that users encounter are not mere digitized compilations of documents contained in the nation’s vaults. Archivists, editors, publishers, and the institutions and funders who make their work possible contribute essential expertise. Which version of a speech was the final draft? Was a letter actually received? How much would awareness of a contemporary rhetorical convention substantially affect understanding of its author’s meaning? Our responsibility to the men and women who created the original primary source materials, and to the public for whom these papers are history, heritage, and cultural inheritance, requires attentiveness to these kinds of questions.

The ultimate question to be asked here is how we can ensure that these documentary editions continue to be produced with appropriate expertise and reach the widest audience. The digital revolution provides not only new means for producing and providing access, but also new opportunities for historical scholarship in the production of these projects. The world in which we research, write, and disseminate our work is changing, and expanding online publishing of historical records increases their utility, value, and appeal.

Similarly, the needs of digital government present challenges to state archives. The creation of government records in digital form can be vital for engaged citizenship, but also raises challenges for their preservation and use. To that end the AHA also supports the NHPRC’s move to provide funding to state archives in preserving and providing access to electronic government records.

Digital publication of all NHPRC projects will broaden access. The proposed transition period of four years, as well as funding to support the move to digital, will help projects to build sustainable digital resources, but that access involves new ongoing costs for elements such as preserving the digital files and creation of vital metadata. The expense of producing these works in either print or digital is significant, and publishers must be able to recoup their investment.

At the same time, these edited documents are a public good, and there are reasonable obligations that accompany public funding. Publishers can, for example, be reasonably required to complement a subscription model for digital publication with free access to secondary school students and teachers. This is not a matter of balancing diverging interests: everyone involved in the ecosystem—the institutions at which projects are based, the publishers, the archivists, the editors, and the funders—have an obligation to encourage both wide circulation and sustainable models of high-quality production.

Sincerely,

James Grossman
Executive Director

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