Public Comments Submitted by Drew Clark on April 7, 2022
Good afternoon,
I hope you are well. I viewed the April 2022 FOIA Advisory Committee meeting and really appreciate the opportunity to do so. I had some comments about the draft recommendations from the First Person Subcommittee.
Re: the EOIR-inspired recommendation (#1?) - I recommend staying away from the term "individual" so as not to confuse with the defined term "individual" in the Privacy Act. I would recommend "person" instead.
Re: recommendation #4 - has the subcommittee explored the possibility of getting DHS OIG to look into the A-files problem? This might be a more palatable and cost-effective solution than the NGO solution the subcommittee seemed to be proposing. IGs develop their audits, inspections, and evaluations based on encouragement (or mandates) from Congress and other stakeholders. I guess my overarching question would be: did the subcommittee engage with DHS OIG about this at all? (I had to step away for a moment when this was being presented, so I apologize if this was addressed during Mr. Susman's comments.)
V/r,
Drew Clark (he/him)
Training Program Manager
Coordination and Oversight Team | Departmental FOIA Office
Office of the Solicitor | U.S. Department of the Interior