Virginia Records Managers, 
                I have been alerted to a proposed change in the Virginia
Public Records Act (VPRA), via House Bill # 1791, which impacts upon all
of us. State localities as well as agencies will be impacted by this
change. As a member of VAGARA, and the Records Manager at Virginia Tech,
I believe I should bring this your attention, and hopefully action. I
have reviewed the proposed VPRA changes and am asking you to do the same
and to provide the Library and your House Delegate your assessment on
these changes, as I have herein:
                My primary concern in the proposed VPRA is the lack of
Audit, IT,  and Legal input to the Library Board Duties/Powers, as well
as expertise with State Locality's records programs, which is not
currently possessed within the State Library. I'd like to see the VPRA
require a State Records Advisory Council be formed with membership
consisting of, at minimum, four persons with the expertise to which I
have just referred, namely: audit; legal; IT ;and State Locality records
experience ( hopefully 2-3 years worth) to serve as an advisory
committee to the Library Board. 
                There are three other changes, as well as two omissions,
in the re-write, which I do not consider minor, and which disturb me:
                1. We should rethink deleting the large number of
"definitions", which may be readily apparent to those of us in the
business, but may offer needed insight to our business by readers who
are not from within the records community. We might even want to think
about increasing the definitions to make our business more friendly to
the General Public readers of this Bill. 
                I'm most disturbed about deleting references to
"electronic" records and the expanded description of the medium
discussed in the definition of "Public Record". One of my most important
messages to the university community is to get them to understand the
breadth of the records issues, particularly those in electronic and
other-than paper, hard copy formats. You see, most people still want to
mentally limit all records definitions to the paper form. Modern
technology and innovation, including such things as electronic and
digital signatures, disappearing ink software, and document encryption
systems, continue to play the greatest impact on defining the scope of
our business. They will even more so, into the future. The VPRA should
recognize this reality and include new terminology and technology and
their impacts, rather than delete reference to them. 
                2. In paragraph 3 under the duties/powers of the Library
Board, the proposed deletion of the words "administrative, legal,
fiscal, or historical" leaves a sentence making no sense to me: Once a
record is determined to be of archival value, what could possibly happen
to make it no longer so? 
                3. Under 42.1-83 the deletion of reference to the
Library's microfilm services is understandable given current budget and
staffing restrictions but rather than eliminate this support which most
of us throughout the state would like to see reinstated, why not leave
it with a caveat in hopes that it is a service which be eventually be
restored. SUGGESTION: Simply add between the fifth and sixth words of
the paragraph the words "as equipment and staffing budgets permit, ".
Sentence would then read: The State Library Board shall, as equipment
and staffing budgets permit, formulate and execute a program to
inventory, schedule, and microfilm official
records---etc.---etc....etc." Also, by deletion of the first paragraph,
it makes no sense to me, in the following paragraph to state that
Microfilm will be stored at the Library once you delete the first
paragraph. 
                4. I also see no reference to responsibilities of the
State Library to provide the records management training critical to the
success of our business. I think the VPRA should so designate these
responsibilities.
                5. Finally, I'd like to see the Library Board, with my
recommended Advisory Council input, create and promulgate a formal State
Records Policy from which all State agencies and State localities can
draw to create there own.
This e-mail is not an effort to ask for your agreement with my input
above. My purpose in writing is to encourage you to make your thoughts
known to the Library Board and to your respective Delegates. I think you
will agree, the final content of  Bill #1791 will affect each and every
one of us. 

Jerry Palmer 
University Records Manager  (0522)
Virginia Tech
(540) 231-8320 
Be like a postage stamp, stick to one thing until you get there.


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