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this twitter thread gives a much clearer explanation of what is taking place
and this from the National Archives
Many of our readers may have seen recent items in the news media, social media or on listservs that make it seem like the Department of the Interior is making an unusual request to destroy Federal Records. We have been busily responding to inquiries about this schedule from individuals and the press for a few days. Those of you who work in records management understand the records scheduling process, but to others, this process can seem mysterious.
“My concern is with mineral and oil and gas lease records related to tribal land”
this destruction request has nothing to do with those records
My concern is with mineral and oil and gas lease records related to tribal lands. Indians have a hard enough getting an accounting of lease royalties as it is.
Something a lot of people are missing is that the scientific data tends to be duplicated in other records that are being kept as permanent.
For example, the lamprey data is currently scheduled under NC1-22-78-1/39, which means the schedule was written in 1978. The Lamprey was approved as temporary in 1978 because it was much of the data was included in technical publications that were permanent. Given that FWS has been using that disposition for 40 years now without any complaints, I fail to see why it is suddenly a problem now.
Item 0011 you mention where the appraisal dossier states it has “scientific worth” also states that it is “Captured elsewhere in permanent records.”
“the DOI’s proposed schedule consolidates 411 record groups into just 23.) One potential downside is that records could be harder to find.”
The records will still be accessioned to the National Archives using their current record groups, even if they are scheduled under RG 48. Creating Department Record Schedule, which is what the DoI is attempting to do, is much like the current practice of using the General Record Schedule governtment wide for common types of records, or using Army-wide, Air Force-wide, and Navy-wide schedules for the respective military services even though the records might end up in different record groups based on exactly which agency or command within their services.