Openness groups submit comments on OMB’s “Circular A-130” guidance

Today,, Association of Research Libraries, Government Accountability Project, and American Association of Law Libraries submitted comments on the Office of Management and Budget (OMB)’s revisions to the governing document establishing policies for the management of federal information resources. We were joined by 7 other organizations in our coalition.

For the first time in fifteen years, OMB is proposing revisions to its Circular No. A-130, “Managing Information as a Strategic Resource” – a document that has a significant impact on public access to government information, as well as the management of federal records and other resources that are vital to the public interest.

OTG coordinated with our organizations concerned with issues that are importantly affected by Circular A-130; notably, public access to government information, privacy protections, whistleblower protections, and appropriate measures to protect the security of information, information resources, and information systems while ensuring transparency and accountability. 

“Circular A-130 has been the guiding light on fundamentally important laws relating to the management, dissemination, and security of government information,” according to Executive Director Patrice McDermott. “This is the first time in 15 years the public has been able to weigh-in comprehensively on this guidance, and it’s critically important for OMB to consider our suggested revisions in the interest of the public’s right-to-know.”

The deadline to submit comments has been extended, following the request of open government groups, to December 5, 2015. To see the proposed Circular A-130 revisions, view the comments and suggest edits, visit;

The following organizations endorsed the submitted comments on the A-130:

American Library Association
Bauman Foundation
Bill of Rights Defense Committee 
Center for Media and Democracy
Defending Dissent Foundation
Project On Government Oversight
Transactional Records Access Clearinghouse (TRAC)

Background on the Circular A-130

When Circular A-130 was published by the OMB in December 1985, it required agencies to look first to the private sector when planning information activities, and not to disseminate information that the private sector might otherwise sell. The 1985 A-130 had a number of problematic effects that arose from its characterizing public access to information as a matter of the public’s having to request information that belonged to the government (with only limited government obligations to disseminate information before it was requested). Despite later changes in the governing law and the 1994 improvements to the Circular, the essence of the regulation that information held by the government was government information – and not information the public necessarily had a right to access – prevailed at the OMB.

In 1993 and 1994, the Clinton Administration re-wrote Circular A-130, significantly changing information policy and practices across the executive branch. This signified a sea change from the 1985 Circular, as it changed fundamental principles within the guidance, emphasizing that the values of democracy critically rely on the public’s right of access to government information.  For example, it stated explicitly that “Because the public disclosure of government information is essential to the operation of a democracy, the management of Federal information resources should protect the public’s right of access to government information.”

In April 2000 OMB revised the Circular A-130 to, among other things, account for new laws and guidance relating to information technology management in federal agencies.

For more on the history of the Circular A-130, see Patrice McDermott’s “Who Needs to Know? – The State of Public Access to Federal Government Information.” 

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