federal geospatial information coordination and consolidation

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Federal Geospatial Information Coordination and Consolidation Nathan Lowry, Colorado Springs, 24 February 2015 Note: The views expressed in this paper are mine alone and do not intentionally represent those of my employer, academic institutions that I attend or professional associations in which I am involved. Since 1990, the United States Federal Government has instituted a policy of managing geospatial (digital mapping) information across agencies under a coordinated stewardship model between departments. This National Spatial Data Infrastructure (NSDI) assumes that federal agencies will steward and provide access to foundational nation-wide datasets for the benefit and efficiency of the government as a whole. This concept was encapsulated in the Office of Management and Budget (OMB) Circular A-16 (revised), Executive Order 12906 (amended), and finally in Sec. 216 of the e-Government Act of 2002 (44 USC § 3501). Further work this decade to clarify and enforce the concepts in law and policy have developed OMB Circular A-16 Supplemental Guidance and a National Geospatial Data Asset Management Plan. Nevertheless, progress towards the objectives founded in circular A-16 has been irregular and slow to be fulfilled by the various government agencies responsible. Recently, the Government Accountability Office (GAO) has released reports criticizing federal departments and agencies for their lack of progress and Congress has introduced legislation suggesting that a more radical approach may be necessary to effectively coordinate and/or consolidate the mapping activities of federal government agencies. This paper will examine the proposals by the GAO, Senator James Risch’s and Congressman Doug Lamborn’s offices and alternatives, and provide a qualitative analysis of the effectiveness of the proposed solutions and suggestions for areas of more research or development activity.

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Since 1990, the United States Federal Government has instituted a policy of managing geospatial (digital mapping) information across agencies under a coordinated stewardship model between departments. This National Spatial Data Infrastructure (NSDI) assumes that federal agencies will steward and provide access to foundational nation-wide datasets for the benefit and efficiency of the government as a whole. This concept was encapsulated in the Office of Management and Budget (OMB) Circular A-16 (revised), Executive Order 12906 (amended), and finally in Sec. 216 of the e-Government Act of2002 (44 USC § 3501). Further work this decade to clarify and enforce the concepts in law and policy have developed OMB Circular A-16 Supplemental Guidance and a National Geospatial Data Asset Management Plan. Nevertheless, progress towards the objectives founded in circular A-16 has been irregular and slow to be fulfilled by the various government agencies responsible. Recently, the Government Accountability Office (GAO) has released reports criticizing federal departments and agencies for their lack of progress and Congress has introduced legislation suggesting that a more radical approach may be necessary to effectively coordinate and/or consolidate the mapping activities of federal government agencies.This paper will examine the proposals by the GAO, Senator James Risch’s and Congressman Doug Lamborn’s offices and alternatives, and provide a qualitative analysis of the effectiveness of the proposed solutions and suggestions for areas of more research or development activity.

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Page 1: Federal Geospatial Information Coordination and Consolidation

Federal Geospatial Information Coordination and Consolidation Nathan Lowry, Colorado Springs, 24 February 2015

Note: The views expressed in this paper are mine alone and do not intentionally represent those of my employer, academic institutions that I attend or professional associations in which I am involved. Since 1990, the United States Federal Government has instituted a policy of managing

geospatial (digital mapping) information across agencies under a coordinated stewardship

model between departments. This National Spatial Data Infrastructure (NSDI) assumes

that federal agencies will steward and provide access to foundational nation-wide datasets

for the benefit and efficiency of the government as a whole. This concept was

encapsulated in the Office of Management and Budget (OMB) Circular A-16 (revised),

Executive Order 12906 (amended), and finally in Sec. 216 of the e-Government Act of

2002 (44 USC § 3501). Further work this decade to clarify and enforce the concepts in

law and policy have developed OMB Circular A-16 Supplemental Guidance and a

National Geospatial Data Asset Management Plan. Nevertheless, progress towards the

objectives founded in circular A-16 has been irregular and slow to be fulfilled by the

various government agencies responsible.

Recently, the Government Accountability Office (GAO) has released reports criticizing

federal departments and agencies for their lack of progress and Congress has introduced

legislation suggesting that a more radical approach may be necessary to effectively

coordinate and/or consolidate the mapping activities of federal government agencies.

This paper will examine the proposals by the GAO, Senator James Risch’s and

Congressman Doug Lamborn’s offices and alternatives, and provide a qualitative analysis

of the effectiveness of the proposed solutions and suggestions for areas of more research

or development activity.

Page 2: Federal Geospatial Information Coordination and Consolidation

Background

Mapping information has always been important to the U.S. government. Domestic

mapping programs were developed and maintained during the course of history from

early settlement, through the colonial period, and throughout the 19th and 20th centuries.

However, the geospatial information technologies envisioned and piloted in academic

settings in the 1960 began to be employed by federal agencies in the 1970’s and 80’s who

sought to use computers to help manage their burgeoning census, domestic mapping and

land management missions (Robinson 2008, Usery, Varanka and Finn 2009, US Census

2014, Hope 2003). The growth of these means of management spawned a fledgling

private industry that at first was designed to support these agencies. These organizations

began developing cartographic methods, database use, and computational software that

later in the 1990’s and 2000’s became a thriving commercial geospatial software and

consulting services industry – not only to federal, state, local and international

government agencies but also to natural resource (timber, mining, oil and gas),

agriculture and engineering fields. “When the federal government was the primary data

provider, regulations required data to be placed in the public domain. This policy jump-

started a new marketplace and led to the adoptions of GIS capabilities across public and

commercial sectors.” (NGAC 2009, 12)

Because of their position as early adopters of geospatial technologies in the last quarter of

the 20th century, US federal agencies began to realize earlier than most that the practice

of managing geospatial data and the shared use of that data required system independent

data standards in order for collaborative use to be effective. They also began to realize

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that the data that they had developed at great expense would need to be reused to in order

to preserve and maximize that investment. Leveraging over a decade of experience and

lessons learned by federal land management other federal agencies, the Office of

Management and Budget (OMB) revised Circular A-16 in 1990. OMB Circular A-16

(revised) established the Federal Geographic Data Committee (FGDC) and introduced the

concept of the National Spatial Data Infrastructure (NSDI), digital shared geospatial map

data for the nation produced and maintained by national, state, local, private industry and

non-profit entities in the United States. These principles were endorsed in 1994 by the

President with Executive Order 12906, and by Congress in law through the e-

Government Act in 2002 (44 USC § 3501).

During the first decade of the FGDC, the vision, productivity and role of the FGDC with

respect to the geospatial data industry was very influential. They created a descriptive

metadata standard, normative standards such as the National Standard for Spatial Data

Accuracy (NSSDA), thematic mapping content standards for land ownership boundaries

and soils, and classification standards for wetlands and vegetation.

The first decade of the 21st century was marked with incredible growth in the geospatial

technology and services industry. Geospatial intelligence and geospatial data supporting

homeland defense became a principle means for protecting citizens, infrastructure and the

environment after September 11, 2001. Large-scale natural disasters (eg. hurricane

Katrina, the Banda Aceh tsunami) and man-made events (NASA’s Columbia tragedy,

London’s transit bombings) – both foreign and domestic – further increased demand to

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account for and investigate means to secure people and property in their situations. In

consequence, during this time period outside influences began to dramatically influence

the FGDC. In 2004, a disruptive effort initially outside the FGDC but within the US

federal government known as Geospatial One-stop quickened federal geospatial data

access and standards adoption efforts; it established a single geospatial data portal for the

US (now data.gov) and prioritized 8 NSDI framework layers, publishing standards for

their implementation (FGDC 2005). To meet the objectives outlined in OMB Circular A-

119, the FGDC departed from taking lead roles in standards publication in 2005 and

demonstrated their commitment in 2010 by adopting 64 (sixty-four) International

Standards Organization Technical Committee for Geographic information and Geomatics

(ISO TC 211) as well as other outside standards (FGDC 2010). Several agencies and

individuals during this time period expressed that the FGDC was not responsive enough

to the needs and requirements of federal agencies and those served by them (D.

LaBranche, personal communication, January 2008). The National Geospatial Advisory

Committee (NGAC) was established in 2008 to make further recommendations to the

FGDC and chart its stated progress on goals and objectives (OMB 2008). This period was

more transformative and yet highly productive in comparison to the previous decade in

the number of work products produced the by FGDC.

This second decade of the 21st century, the third for the FGDC, in terms of geospatial

data and program management has the capacity for further change – for the FGDC and

for the federal government at large. Culturally, we are in a different age with respect to

geospatial information than we were 25 years ago when the FGDC was created, or even

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10 years ago when Google Earth launched an explosion in interest in geospatial data

among the public for that matter. The rise of commercial consumption of geospatial

information via the World-wide Web and its increasing consumption via mobile

applications has made the expectation of access to this information ubiquitous for most

public consumers. The political value of geospatial data to provide an understanding of

the land, infrastructure, and the environment has been non-partisan, especially in

response to large-scale disasters.

Current Structure, Authority, and Resources of the FGDC

Today, the FGDC is required by law (44 USC § 3501), directed by Executive Order (EO,

12906 amended) and OMB circulars (esp. A-16 revised), and co-chaired between OMB

and the Department of Interior (DoI). This committee is inclusively representative of

many US federal government departments but disproportionately represented by federal

civil agencies that produce and maintain geospatial data. It underrepresents defense

agencies and especially federal agencies that are largely consumers of geospatial data.

This may be a matter of history as the committee’s origin was largely organized from

civil agencies charged with responsibilities for multi-purpose domestic mapping (USGS),

demography (US Census) and the management of public lands – for example the Bureau

of Land Management (BLM), the US Forest Service (USFS) and the National Parks

Service (NPS), etc.

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The law, the EO and OMB circular grant the FGDC authority to set standards, plan

direction, and coordinate the activities of geospatial programs among federal agencies.

However, the FGDC holds neither the authority to enforce compliance nor to redirect or

cancel geospatial program efforts of any federal agency. Most importantly, it does not

exercise budgetary authority over any agency. OMB is supposed to exercise this

authority for the FGDC in the budgeting process, but OMB lacks the means and expertise

to be able to measure geospatial data acquisitions or the interest to do so (GAO 2013).

OMB admitted, “The players traditionally active in the Federal agency budget formation

process, most notably the agency CFO community, rarely have expertise in geospatial

management or issues. At the same time, those with significant geospatial expertise rarely

have a distinct role in the budget process” (2010, 28).

A key concept enshrined in EO 12906 and OMB Circular A-16 is the notion of a National

Spatial Data Infrastructure (NSDI), which within A-16 is broken down into nation-wide

themes (transportation, water, land ownership, jurisdictional boundaries, etc.) that are

stewarded by agencies that are explicitly listed by OMB in appendix A of A-16 as

responsible for them. In 2010, OMB published supplemental guidance for Circular A-16

which established a rubric for assuring the stewardship of the NSDI data themes,

definitions, and lead agencies and to update these in the Circular through a deliberative

process in response to changing goals and priorities for the federal government. More

recently, the FGDC has developed the National Geospatial Data Asset Management Plan,

which (among other reporting) requires a deliberate annual accounting per theme by

responsible department to the FGDC and OMB (FGDC 2014).

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Criticism of the FGDC: The Government Accountability Office (GAO) Formal criticism of the FGDC and its current scope and direction is limited. Those that

are most apt to criticize are also supported by or expected by others to provide support for

the FGDC. This includes the National Geospatial Advisory Committee (NGAC), the

Congressional Research Service (CRS) and the National Research Council (NRC). The

Management Association of Private Photogrammetric Surveyors (MAPPS), as a

representative association of private industry, is sometimes quite vocal in its criticism of

the federal government and its civil geospatial programs (NRC 2014). Other sources of

criticism include that from academic institutions, editorials, and individuals’ blogs.

Perhaps the most substantial and credible criticism to date may be from the Coalition of

Geospatial Organizations who most recently published the Report Card on the US NSDI

(COGO 2015). Although they represent geospatial data practitioners who have financial

interests that may benefit from continued or increased federal government spending in

geospatial data, the breadth of their representation by public service, private business and

professional association member organizations and the fact that any statement from

COGO requires unanimous consensus by these organizations adds considerable

credibility to their claims.

The GAO has recently taken special interest in reviewing the law, policy, and practices

that currently defines the actions of the federal government for geospatial data program

management and coordination, and is holding the FGDC and federal agencies

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accountable to comply with existing policy. In 2012, the GAO published “OMB and

Agencies Need to Make Coordination a Priority to Reduce Duplication” (GAO-13-94), a

follow-up statement “Geospatial Information: OMB and Agencies Can Reduce

Duplication by Making Coordination a Priority” (GAO-14-226T) in 2013, and is

continuing its active review of the geospatial program activities of the FGDC and federal

government agencies this fiscal year (FY 2015). The GAO is likely to keep the “heat on”

as many of the conditions in 2012 had not significantly changed since their 2004 review

(GAO 2004).

Leading recommendations from GAO-13-94 were to establish persons of responsibility

(e.g. in departments and for themes), deliberatively plan and establish milestones,

measure performance to assure timelines, and share forecasts of geospatial data

acquisitions. While these efforts are noble, and accountability for departments executing

geospatial programs and the OMB were sorely needed, it is difficult to say that an

organized, coordinated and fiscally responsible federal government with respect to

geospatial program investments will be achieved through compliance to existing law and

policy: “enforcement alone may not be sufficient to meet the current challenges of

management, coordination, and data sharing” (Folger 2011, 16). A persistent focus by the

GAO on three large civil data producers – the USGS, the National Oceanic and

Atmospheric Association (NOAA), and the US Department of Transportations’ Bureau

of Transportation Statistics (BTS) – may indicate some systematic issues, but will never

redirect the redundant efforts of the federal government as a whole because the scope is

too small. For example, the appetite for largely consuming agencies to redundantly

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purchase, land ownership or address location data by the Department of Housing and

Urban Development (HUD), the Department of Homeland Security (DHS), the Federal

Bureau of Investigation (FBI), the Small Business Administration (SBA), the Federal

Deposit Insurance Corporation (FDIC), and the Federal Reserve, will not be abated as

none of these are within the departments under current review (GAO 2013, 9). Success in

implementation cannot solely be attributed to planning, goals and performance measures

but depend foremost on the commitment and will of those agencies that have

responsibilities to manage geospatial themes under Circular A-16. GAO’s assumption

that the FGDC (primarily the DoI with support from OMB) would be able to successfully

communicate and coordinate among agencies that may have neither interest nor

motivation to attend and participate with the Committee to prevent redundant investments

among them is lofty. GAO’s focus in their reports is only on compliance with existing

law and policy and not on any relevant needs to change these. The GAO should be

motivated to do more; change to law is the primary domain of Congress, whom the GAO

serves. The NGAC, in contrast, has been much bolder: “establish a geospatial leadership

and coordination function immediately within the Executive Office of the President.”

(NGAC 2008, 2).

Congressional Legislation

Congressman Doug Lambert’s (R-CO) Map It Once, Use It Many Times Act (MIO-

UIMTA) is not the first bill introduced in Congress that has attempted to significantly

change federal government geospatial management in the age of the FGDC. The

National Intelligence Reform Act of 2004, for example, established the Office of

Page 10: Federal Geospatial Information Coordination and Consolidation

Geospatial Management within the Office of the Chief Information Officer in DHS (6

USC § 343). The E-Government Act of 2002 (44 USC § 3501) has previously been

cited. However, Rep. Lambert’s MIO-UIMTA is the first bill introduced that intends to

radically change the organization of civil geospatial portfolio management in the federal

government since 1990.

Introduced to the 112th Congress in 2012, and reintroduced in the 113th Congress, MIO-

UIMTA has several things going for it. One of the most effective means for GIS

coordination offices in government is a short chain of command (J. Robillard, personal

communication, 2006). The Map It Once, Use It Many Times Act certainly meets that

objective: “The Administrator shall be appointed by the President, by and with the advice

and consent of the Senate.” (11). The Administrator answers directly to the Secretary of

the Interior and manages her own agency, the National Geospatial Technology Agency

(NGTA) within the department (10). It establishes a National Geospatial Database

(NGD) – to include seven NSDI (fundamental) framework layers and data for utilities

(power, fuel, communication, water, sewer), recommendations for real property

management and “other geospatial data [as] determined by the Administrator” (11-13).

The content of the NGD is comprehensive in nature. It is to be public – yet with broad

exclusions for National Security (14). It even tries to resolve Title 13 protection of the

US Census National Address Database (NAD) by declaring address data from the Census

public so long as the privacy of individuals is preserved (20). It requires “return on

investment analysis” as well as a reasonably comprehensive research agenda (37-41).

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The most defining features of the legislation is 1) the consolidation of all geospatial

management for the DoI, the US Forest Service, and the National Oceanographic and

Atmospheric Administration (NOAA) (17-19) and 2) explicit favoritism towards

privatization of federal government geospatial data production (28-36). The FGDC and

NGAC in the legislation are replaced by the similarly constituted (but separately

mandated) National Geospatial Policy Commission that advises the NGTA (22-28).

This Commission and the NGTA Administrator oversee all activities of the consolidated

agency (10-11, 14-15, 22-24). The Commission also makes recommendations to expand

the NGTA to other agencies and departments and explicitly makes recommendations for

privatization activities (23-24).

There are a few issues with this legislation. First, centralization never seems to work out

the way it’s planned. State and local governments, for example, who consolidate their

geospatial professional staff into a single agency often (but not always) find stiff cultural

resistance from those functions who use geospatial technologies to support their

respective agency missions (B. Goodack, personal communication, July 2013 regarding

City of Colorado Springs consolidations). Resentment and resistance can persist for years

yielding decreased productivity (J. Gottsegen, personal communication, January 2012

regarding prior State of Colorado consolidation efforts). Second, this seems to be a very

partial centralization. Does the legislature intend for the NGTA to grow? The potential

for growing the NGTA by absorbing geospatial functions of other agencies is suggested

(24) but not proscribed. If further changes are deemed necessary of the Executive branch

– including studies by the Commission and the NGTA, will it take another act of

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Congress to enact? Most important: why not look at all geospatial functions of the

federal government for any prospective reorganization? If the problem is that the US

federal government wastes money by duplicating expenditure for geospatial data

(and hardware, software and personnel) required across many agencies and

underfunds activities that could most effectively and efficiently meet those needs

(my assertion), then more time needs to be spent understanding the problem culturally,

procedurally, organizationally and comprehensively in order to craft the right solution.

Funding for the NGTA through this legislation could be a real problem, as it is left open

ended (14). The legislation includes the possibility of operating by general appropriations

but it also suggests the establishment of user fees to fund the NGD (14). This is creative,

but not consistent with the intent to make the data public as requiring fees for access is

(by definition) not public access. Other suggestions for funding expressed in (but none of

which are required by) the bill include cost sharing with state and local government and

public-private partnerships (14).

The privatization language is over the top. The bill spends over half of its text describing

the privatization activities of the NGTA and the Commission. This language includes

expressed ideology, detailed contracting processes, and a clear preference for

privatization without regard to aspects of quality, efficiency, or effectiveness among

those functions performed by public service or private industry (28-36). Most of this

language is just overkill; at the very least, it is unnecessary language for a statute, but at

worst, it is a deliberate and explicit effort to create almost a welfare state with a

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government cash cow dedicated to a small branch of private industry. Stranger still is the

provision “the Administrator shall provide data to heads of other Federal agencies for the

determination as to whether any property owned or managed by the United States may be

better managed through ownership by a non-Federal entity, including a State or local

government, a tribal government, a nonprofit organization, or a private entity.” (15) The

Administrator will suggest lands that could be better managed by non-Federal agencies to

the heads of those agencies? The Administrator may have access to data, but data alone

does not constitute expertise for good land management practice. Further, why would

these agencies want to receive, let alone act on any of these recommendations? (Timoney

2013)

Congressman Lamborn’s legislation is well publicized. He appeared on the cover and

wrote the “View From The Hill” article for March 2013 edition of US Geospatial

Intelligence Forum’s magazine Trajectory (Lamborn 2013). Digital news media reported

the intentions of the MIO-UIMTA. (Korte 2013) The publicity might have been in part

an effort to attract a co-sponsor from the Senate; to date, he does not have one.

Senator James Risch (ID), a Republican himself, is putting forward a separate proposal.

A discussion draft entitled the Geospatial Data Act is in closed circulation from his

office. It proposes that the OMB become the chair and the DoI the vice-chair for the

FGDC (5-6). The duties and responsibilities currently being carried out by the FGDC

and the NGAC would be assured in law, with greater investigative powers for NGAC to

review the geospatial program management activities of departments and individual

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agencies of the federal government (6-7, 14-15). Allowing the NGAC investigatory

powers for “management by walking around” in the legislation could be very helpful.

Ideology for the NSDI is also expressed to include respect for privacy and for proprietary

interests of commercially licensed products (17-18). However, the language does not

state that any data access controls are needed to protect national security. The legislation

expresses many of the requirements for managing National Geospatial Data Assets (i.e.

mapping themes) that are currently found in the OMB Circular A-16 Supplemental

Guidance, essentially converting these requirements for goals, plans, and performance

measurement from policy to law (18-24). It also enacts into law the system architecture

of the GeoPlatform to collect federal geospatial datasets from producing agencies and

provide them to consuming agencies and the public (24-25). This is unusual, as

legislation usually defines the need and responsibilities to create information systems, but

most often doesn’t (yet still may) call out a specific system by name, especially without

these definitions.

The Geospatial Data Act (in its 2014 discussion draft form) would require each agency to

1) “include geospatial data as a capital asset for purposes of preparing the budget

submission of the President…” (28), 2) disclose all geospatial data spending (28), and 3)

require biannual audits for the same (29). The most powerful piece of this legislation

requires geospatial data programs to meet performance requirements – or funding for

these programs will be discontinued (30). Statutory budgetary control is the most

compelling aspect of this legislation, however it is hard to say that this and the conversion

of existing geospatial program management policy into law will be enough to implement

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a comprehensive and cost-efficient geospatial program within the civil sector of the

federal government.

Ed Cox, legislative assistant for Senator Orrin Hatch, UT (R) reported at the NSGIC Mid-

year meeting (24 Feb 2015) that Senator Hatch would be introducing the Geospatial Data

Act to the 114th Congress.

Models for Geospatial Portfolio Management

One of the earliest concepts to take hold in the United States outside of the federal

government in the FGDC era was the concept of the Geographic Information Officer or

GIO. California was among the first states to adopt this concept in 2000, where a GIO

would have central responsibility to organize, manage, and control geospatial programs

of departments under the authority and direction of the State CIO (Esri 2002). Many

other states followed suit. The concept became even more common among local

governments. For example, by 2000 the City of Sacramento had established a core office

of responsibility for geospatial support and management. This office was responsible for

the management and maintenance of software, servers, and support personnel that would

enable practitioners with geospatial technologies within departments to maximize the

value of their time in using geospatial data and analysis to support their departments

missions, e.g. criminology for the police or tree management for parks and recreation

(Lowry 2000). Such hub-and-spoke models have become so common among states and

large local governments now that they are more likely the rule than the exception.

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The USGS also recognized such a position in 2000 (Esri 2002). By 2006 the Department

of Defense had created geospatial program offices for each Service and the Office of the

Secretary of Defense (LeBranche 2014), and by 2007 the United States Air Force

(USAF) established Geospatial Integration Offices (GIOs) for most major installations

(Lachman et al 2007). However, to date the federal government lacks central authority

and funding control to do the same across the US government enterprise. NSGIC went

further and looked carefully for the best management practices among state geospatial

programs and identified 10 criteria for a “model” state program (NSGIC 2004). Such

concepts could certainly be better entertained for the federal enterprise.

Another model to consider is that of the US intelligence community. Funding for many

intelligence activities, particularly the NSA, NRO, and NGA as part of the National

Intelligence Program (NIP) is centralized under the authorities of the Director of National

Intelligence (50 USC § 3024). NIP operations range from the FBI in the Department of

Justice, the CIA in the Department of State, and the NGA, NRO, and NSA in the

Department of Defense. But regardless of the agency and its duties under its parent

departments, intelligence activities are funded separately. A funding model for

geospatial activities that controls resources but also allows these personnel to continue to

support their agency directly could be considered. Such a model also allows for the

aggregation of human resources to meet needs and agency tasks, prioritized with respect

to national goals (50 USC § 3024).

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It is surprising to think that the NSDI, envisioned as an organized activity of aggregating

geospatial data from local to state to national, isn’t yet organized on common public

administration principles of intergovernmental relations (IGR). Since the 1960’s, the

U.S. federal government has funded transportation, welfare, education and agriculture

programs through the states and local agencies that largely execute the work (Wright

1974). With a clear need for uniform consistency of data availability and quality, it is a

wonder why a federated approach like these hasn’t taken hold with geospatial programs

of the US government. For example,

“beginning in 1981 Congress amended the original [Community Development Block Grant] CDBG to allow state governments, instead of officials in the Department of Housing and Urban Development (HUD), the opportunity to administer the nonentitlement or discretionary funding portion of the CDBG program. Cities with populations under 50,000 and counties with 200,00 or fewer residents could receive grants based on funding priorities and award criteria established by state governments. The funding under this part of the CDGB program is not an entitlement, for the state governments have discretion in choosing grant recipients. Small cities and counties are not required to match grant funds with local funds in order to be eligible for these CDBG funds. As in the enititlement program, however, states must ensure that “maximum feasibility priority” goes to funding programs that benefit low-to-moderate-income persons and that prevent or eliminate slums or blight. … Currently, forty-nine state and Puerto Rico participate in the state-administered, nonentitlement CDBG program, for which the FY 2010 appropriation totaled about $1.2 billion.” (England, 2012)

The efficiency and uniform quality of such a concept to execute the NSDI seems very

obvious. NSGIC observed, “The federal government must not dictate the actions of state

and local governments, nor should state governments dictate those of local government.

However, each level of government can exert a strong influence on subordinate levels by

making funding contingent on compliance with the policies and standards it establishes”

(NSGIC 2008). NGAC compares this possible relationship among government levels to

that of transportation, where the federal government largely appropriates (raises) the

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funds to sustain roads, the states divide the funds among local governments, and the local

governments execute the maintenance of these roads (NGAC 2009). It is likely that such

uniform IGR systems haven’t developed to support the NSDI in the US because of the

top-down origination of geospatial data production. Some federal agencies persistently

produce national datasets at great expense (Weinberg 2011) while others abdicate (Snook

and Kirkpatrick 2014), recognizing that they just don’t have the resources to develop or

sustain them on their own. Some federal agencies accustomed to producing geospatial

data have been slow to trust that sourcing through federated state and local governments

or private industry might meet their needs with consistency and efficiency.

Some federal agencies may have legitimate efficiency and accountability concerns in

execution through a middle management agency like state government, and local

governments may have equally legitimate concerns about state discretion that may not be

to their benefit and the lack of autonomous self-representation to advocate for such

federal funding directly. Nevertheless, these concerns should be weighed and mitigated

against the value of assured funding to develop and sustain local sources of common map

layers meeting national standards at potentially the least cost.

Another large area with room for greater consideration is the possible integration of

activities between federal civil agencies and the defense department. The National

Geospatial-Intelligence Agency (NGA), the largest of all US government geospatial

program agencies, and the geospatial intelligence, warfighting, and installation

management programs within the armed services have great capacity to share software,

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data, personnel, and even hardware and applications that could support sister civil

agencies in a meaningful and compatible way. With great capacity comes the economy

of scale for great efficiency. Yet legal and cultural constraints prevent taking advantage

of shared resources between civil and defense geospatial programs. Since

Reconstruction, service men and women are expressly forbidden in US law to be used as

local law enforcement (18 USC § 1385). This principle of forbidding posse comitatus to

the military has been interpreted broadly with a thick, tall wall between civil and defense

authorities; yet it may not need to be in all cases. After September 11, 2011, DHS was

funded to collect imagery in 133 urban areas within the US. This new department largely

lacked the expertise manage the work so funding for the program went to NGA. NGA

managed the funds and defined the requirements but the USGS mobilized the work

through their contracts and organized public and private partnerships to defray cost

(USGS 2009). Such close cooperation between defense and civil agencies could be

extended for example, by allowing greater use of US Army Corps of Engineer contract

vehicles by civil agencies, greater cooperation in geodesy modeling between the NGA

and the National Geodetic Survey (NGS) and in other areas where defense agencies are

clearly not performing law enforcement. If Congress is serious about controlling cost and

eliminating duplication and waste among agencies that use geospatial information, they

must look at the largest expender of such funds, the Department of Defense, and its

largest geospatial programs agency, NGA.

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Some argue that geospatial data provided by the US government (or from any

subordinate state or local government in the US) is irrelevant in a day when there appears

to be a plethora of available map data from commercial sources (Timoney 2013). 2012

Republican presidential contender Gov. Tim Pawlenty suggested that government should

not perform any service ably provided by the private sector (CNN 2011). With respect to

geospatial data, some counter-argue that these commercial enterprises (e.g. Google)

would not have been able to be so easily successful without the abundance of public data

available from government agencies to the commercial sector from which most of the

data likely originated (Palatiello 2013). Nevertheless, the libertarian question about

whether governments should be collecting and maintaining mapping information when

the commercial sector may be able to do so requires serious consideration given the rise

and seeming independence of commercial companies to proliferate geospatial

information for the US and worldwide (Onsrud et al 2004). However, the level of

quality, documentation, and sustainment by the private market for licensed commercial

mapping information needs further investigation. Geospatial data produced for

government agencies by contract has a relatively strong history of industry standards for

quality and documentation, where the level of quality measurement and type and depth of

documentation among licensed products appears to vary widely (Boone et al 2007,

Baraclaugh 2010). And as some products and providers of licensed geospatial data are

quite new to the market, it is not yet clear how successfully these products may be able to

be provided over time.

Page 21: Federal Geospatial Information Coordination and Consolidation

Recommendations

While compliance to law and policy among federal agencies with geospatial investments

is warranted, the current scope of investigations by the GAO is too narrow. Not only

does the GAO’s focus not include those federal agencies most prone to consume (and

therefore redundantly purchase) national geospatial datasets, but also excludes the vast

resources and expenditures of the Department of Defense (DoD). The inclusion of NGA

and other geospatial programs of the DoD will greatly aid in understanding the personnel,

software, and data of equal interest to the management of lands and missions within the

US homeland. The GAO should review the redundancy of work among levels of

government nationally and examine the value and effectiveness of programs that federate

data development and maintenance among state and local governments. GAO should

also compare private industry data sourcing options with current public means, including

contracted production, the use of licensed commercial data, and publically accessible

commercial or open source alternatives and examine both the risks and benefits of using

these options.

Congress in its legislative proposals should cast a wide net and include all federal

agencies that produce or consume geospatial data to perform core duties for any

cooperative or consolidated approach and establish an office of primary responsibility

that has authority across these agencies to assure compliance with law and policy and

control over the disbursement, redirection or cancellation of funds. This office must have

the technical expertise to measure the value of work proposed by federal agencies and the

ability of these agencies to carry out this work feasibly – not only to accomplish the goals

Page 22: Federal Geospatial Information Coordination and Consolidation

and missions of their agencies but also to provide reusable and highly valued datasets for

all agencies across the federal enterprise to benefit the economy of, safety of, and protect

the environment for the American public.

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