COMMENTS ON OMB 

CIRCULAR A-16 AND THE 

GEOSPATIAL POLICY 

FRAMEWORK

					

A	Paper	of	the	National	Geospatial	Advisory	Committee

December 2016
NGAC	Policy	Framework	Paper

December 2016

National	Geospatial	Advisory	Committee	(www.fgdc.gov/ngac) 1

I. Introduction	and	Overview

The	National	Geospatial	Advisory	Committee	(NGAC)	received	guidance	from	the	Federal	Geographic	

Data	Committee	(FGDC)	in	2016	to	provide	perspectives	and	advice	on	how	OMB	Circular	A-16	and	the	

geospatial	policy	framework	might	be	updated	to	reflect	changes	in	technology,	organizational	

capabilities,	partnerships,	and	the	evolution	of	the	geospatial	community.	The	NGAC	Policy	Framework	

Subcommittee	met	with	the	FGDC	team	and	reviewed	OMB	Circular	A-16	and	the	A-16	Supplemental	

Guidance	prior	to	developing	this	paper.	

The	NGAC	believes	OMB	Circular	A-16	should	be	updated	and	revised.	The	last	revision	of	the	Circular	

was	in	2002.	The	Circular	does	not	adequately	address	the	current	geospatial	landscape	or	the	essential	

contributions	of	partner	organizations	to	the	National	Spatial	Data	Infrastructure	(NSDI).	Advances	in	

technology,	crowd-sourced	data,	and	a	broader	societal	implementation	of	geospatial	technologies	have	

fundamentally	transformed	the	use	of	geospatial	technology.	Additionally,	communications	styles	have	

evolved	significantly	in	the	past	decade.		

This	paper	highlights	broad	themes	that	should	be	addressed	when	evaluating	the	relevance	of	the	

Circular.		In	particular,	the	Subcommittee	feels	strongly	that	a	complete	rewrite	of	the	Circular,	rather	

than	minor	modifications,	is	needed	at	this	time.	The	Appendix	provides	specific	comments from	NGAC

on	the	existing	A-16,	and	emphasizes	areas	that	should	be	revisited	during	the	revision	process.

The	predominant	themes	of	the	NGAC’s	advice	on	Circular	A-16	focus	on:

1. Enhancements	that	would	better	accentuate	the	value	of	geospatial	information	to	the	nation;

2. The	need	to	manage	resources	to	maximize	the	return	from	public	investments;

3. The	need	for	governance	and	coordination	processes	that	are	inclusive	and	representative	at	a	

national	level, not	just	the	federal	level.

II. Broad	Themes	and	Suggestions	– OMB	Circular	A-16

Background

OMB	Circular	A-16,	Coordination	of	Geographic	Information	and	Related	Spatial	Activities, is	the	primary	

Federal	policy	document	promoting	the	coordinated	use,	sharing,	and	dissemination	of	geospatial	data	

and	activities	supporting	the	NSDI.		OMB	Circular	A-16	refers	to	spatial	data	as	information	about	places	

or	geography	that	have	traditionally	been	shown	on	maps that	can	enhance	understanding	of	our	

physical	and	cultural	world.	

Since	1953,	OMB	has	released	several	iterations	of	Circular	A-16.	These	efforts	were	reinforced	in	1994	

by	Executive	Order	12906,	Coordinating	Geographic	Data	Acquisition	and	Access.	Two	subsequent	laws	

further	reiterating these	responsibilities	are	the	Clinger-Cohen	Act	of	1996	(in	Public	Law	104–106)	and	

the	E–Government	Act	of	2002	(Public	Law	107–347).	In	2010,	OMB	issued	OMB	Circular	A-16	

Supplemental	Guidance.	The	Supplemental	Guidance requires	the	identification	of	specific	datasets	to	

be	managed	in	a	geospatial	portfolio	as	National	Geospatial	Data	Assets	(NGDAs). The	Supplemental	

Guidance	also	clarifies	the	roles	and	responsibilities	of	FGDC	agencies	in	meeting	Circular	A-16	

requirements. Under	the	portfolio	management	process,	NGDA	theme	and	dataset	managers	are	

responsible	for	coordinating	with	partners	as	appropriate,	including	state,	local,	regional,	and	tribal	

governments.
NGAC	Policy	Framework	Paper

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National	Geospatial	Advisory	Committee	(www.fgdc.gov/ngac) 2

The	NGAC	recognizes that	the	purpose	of	OMB	Circular	A-16	is	to	provide	guidance	to	federal	agencies	

for	the	coordination,	stewardship,	and	management	of	federal	geospatial	assets.		After thorough	review,

the	NGAC	encourages the	FGDC	to consider	the	following	points	during	their	evaluation	process.

General	Points

• Circular	A-16	should	be	revised	through	a	collaborative	and	inclusive	process,	incorporating	

input	from	Federal	agencies,	external	partners,	and	stakeholders.	Any	Circular	A-16	revision	

should	incorporate	more	participation into	the	governance	process from	non-traditional	

stakeholders	who	are	geospatial	consumers.	

• The	revision	process	for	Circular	A-16	should	follow	successful	models	such	as	the	process	that	

OMB	and	the	Federal	privacy	community	recently	undertook	to	revise	Circular	A-130	

Management	of	Federal	Information	Resources.	The	revision	process	should	also	include	an	

evaluation	of	what	worked	well, as	well	as	lessons	learned	from	the	current	A-16.

• OMB	should	take	an	active	leadership	role	in	the	revision	of	Circular	A-16.	

• The	Circular	A-16	Supplemental	Guidance,	which	was	issued	in	2010,	should	be	incorporated	

into	the	revised	version	of	A-16.		The	content	of	the	Supplemental	Guidance,	which	describes	a	

portfolio	management	approach	for	NGDA,	should	be	updated	to	reflect	the	recommendations	

of	FGDC’s	recent	NGDA/portfolio	management	evaluation	process.

• Circular	A-16	content	on	data	themes	and	the	NGDAs	should	be	updated	to	include	more	

participation	and	stewardship	from	non-federal	stakeholders.	Some	NGAC	members	feel	there	

needs	to	be	a	national	conversation	and	deliberation	on	which	elements	of	the	NSDI	are	

inherently	governmental	and	at	which	level	of	government;	and	which	data	themes	are	best	

suited	for	the	commercial	sector.

• Circular	A-16	should	recognize	and	specify	the	role	of	the	NGAC	in	providing	external	advice	and	

recommendations	to	the	FGDC	on	national	geospatial	policy	issues.

• FGDC	and	the	Administration	should	also	consider	issuing	a	new	Executive	Order	(EO)	to	replace	

and	update	Executive	Order	12906, “Coordinating	Geographic	Data	Acquisition	and	Access:	The	

National	Spatial	Data	Infrastructure,” which	was	issued	in	1994.		A	new	EO could	complement	

the	updated	Circular	A-16,	describe	an	updated	governance	process,	and	describe	agency	

implementation	actions	and	responsibilities.

• The	new	Administration	should	consider	working	with	Congress	to	enact	legislation	codifying	

the	requirements	of	Circular	A-16	and	EO	12906,	as	well	as	providing	statutory	authority	for	the	

continued	development	and	maintenance	of	the	NSDI	and	the	supporting	activities	of	the	FGDC.

• OMB	Circulars	have	an	inherent	federal	focus	and	are	geared	toward	providing	instructions	and	

guidance	to	federal	agencies	on	the	use	of	federal	resources	in	support	of	national	interests.	

However,	the	NSDI	is	more	a	comprehensive	objective	that	requires	support	and	contributions	

from	the	other	stakeholders.
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• Circular	A-16	must	articulate	the	value	to	the	nation	of	geospatial	resources	as	information	

capabilities,	content,	and	competencies,	rather	than	data	and	processes	of	the	historically	“IT”	

view	of	geospatial	technologies.	The	Circular	should recognize	the	importance	of	the	necessary	

infrastructure	in	the	NSDI	that	supports	geospatial	content	such	as	GPS,	CORS	stations,	and	

Earth	Observing	Systems.

• Circular	A-16	must	recognize	and	differentiate	the	different	roles	of	the	federal	government	in	

the	geospatial	ecosystem.	The	first	role	is	an	aggregator	and	consumer	that	leverages content	

and	capabilities	from	other	levels	of	government	and	the	private	sector.	This is	a	shift	from	the	

traditional	producer role.		Along	those	lines,	recognize	that	some	NGDA	layers	are	inherently	

best	stewarded	from	the	local	government	level	up.	The	second	role	is	that	of	data	creator	and	

steward—recognizing	that	some	NGDA	layers	are	best	stewarded	through	federal	level	

enterprise	programs	that	serve	and	receive	feedback	from	the	entire	public	sector	mapping	

community	where	possible.

• Circular	A-16	should	clarify	how	the	FGDC	will	determine	priorities	for	federal	investment	

activity	in	support	of	the	NSDI	in	collaboration	with	partners	and	stakeholders	including	state,	

local,	regional,	and	tribal	governments.	The	Circular	should	acknowledge	the	pervasive	benefits	

of	smart,	coordinated	investment	in	geospatial	information	and	technology	across	agencies	and	

levels	of	government.		It	should	also	specify	how	partner	agencies	and	organizations	can	

participate	in	and	contribute	to	NSDI	activities	and	resources.	This	process	should	include	a	

mechanism	for	resolving	conflicting	requirements.

• In	addition,	the	new	document	should:

o Update	the	geospatial	governance	structure	and	process	to	ensure	that	the	interests	of	

the	natural,	built,	and	social	environments	are	represented.	

o Focus	on	measuring	progress	and	managing	resources	to	maximize	outcomes	rather	

than	merely	articulating	strategy	or	building	a	resource	quantified	by	size.

o Be	concise	and	as	engaging	as	possible	to	appeal	to	the	broad	geospatial	community	

beyond	the	main	intended	federal	audience.	

o Consider	aligning	stewardship	of	national	datasets	to	existing	and	forthcoming	

requirements	of	essential	government	functions	at	all	levels	of	government.

o Align federal	resources	and	programs	with local	level	programs	and	resources	to	ensure	

success.	Many	other	federal-led	initiatives	(health/social	services,	transportation	

funding,	etc.)	employ	primacy	to	create	a	national	program.		Geography	and	the	NSDI,	

which	relies	upon	data	that	is	inherently	local,	should	not	be	different.

III. Summary

OMB	Circular	A-16,	last	updated	in	2002, requires	a	thorough	update	and	revision.	Circular	A-16 does	

not	adequately	address	the	current	geospatial	landscape	or	all	of	the	Federal	geospatial	players.	The	

Circular	should	incorporate	Circular	A-16	Supplemental	Guidance	(issued	in	2010)	and	have	a	

contemporary,	concise	style.	Any	inclusion	of	the	Supplemental	Guidance	should	ensure	the	ability	to	

make	modifications	to	account	for	future	developments	in	geospatial	information	and	content	without	

requiring	formal	rewrite.	The	document	must	be	clearly	relevant	not	only	to	the	federal	government	but	

the	national	geospatial	community	as	well.	Additionally,	it should	offer	more	detail	on	the	role	of	the	

broader	geospatial	community	in	developing	and	maintaining	the	NDSI.		It	should	recognize	the	
NGAC	Policy	Framework	Paper

December 2016

National	Geospatial	Advisory	Committee	(www.fgdc.gov/ngac) 4

significant	role	non-federal	stakeholders	play	in	the	national	geospatial	community	from	both	a	provider	

and	stewardship	perspective – especially	state,	local,	tribal,	territorial	governments, and	the	commercial	

sector.	The	new	Circular	should	also	articulate	the	value	of	geospatial	resources	as	information	content	

rather	than	data	and	acknowledge	the	pervasive	benefits	of	smart,	coordinated	investment	in	geospatial	

information	and	technology	across	agencies	and	all	levels	of	government.		OMB	should	take	an	active	

leadership	role	in	the	development	of	the	new	document	through	a	collaborative	and	inclusive	process,	

incorporating	input	from	Federal	agencies,	external	partners, and	stakeholders.		The	new	Circular	should	

provide	the	incoming	Administration	with	an	opportunity	to	not	only	strengthen	the	NSDI,	but	also	

provide	a blueprint	for	providing	statutory	authority	for	the	continuing	development	and	maintenance	

of	the	NSDI	and	supporting	activities	of	the	Federal	government	and	the	FGDC.		

This	paper	was	prepared	by	a	subcommittee	of	the	NGAC	that	included	the	following	members:	Tony	Spicci	(CoChair),	Molly	Vogt	(Co-Chair),	David	Alexander,	Bert	Granberg,	Kevin	Pomfret,	Laxmi	Ramasubramanian,	Amber	

Reynolds,	and	David	Wyatt.
NGAC	Policy	Framework	Paper

December 2016

National	Geospatial	Advisory	Committee	(www.fgdc.gov/ngac) 5

Appendix

NGAC	Comments	Specific	to	the	Current	OMB	Circular	A-16

Subcommittee	member	comments	on	the	current	Circular	A-16	language	according	to	the	following	

categories:

1.		What	is	working	well,	and	should	be	preserved?

• The	committee	believes	that	the	rationale	for	the	creation	of	the	current	A-16	Circular	is	

sound	and	a	new	effort	should	be	undertaken	in	the	spirit	of	the	original.

• The	spirit	of	the	document	and	general	concepts	can	be	preserved	but	they	need	to	be	

presented	in	a	more	contemporary	format.

2.		What	is	worth	keeping	but	with	revisions	to	make	it	more	effective	or	successful	in	

implementation?

• The	information	and	concepts	in	the	current	A-16	are	good,	but	a	revised	document	should	be	

presented	in	a	more	engaging	and	compelling	way.

• The	role	of	federal	agencies	needs	to	be	reconsidered	in	light	of	a	geospatial	ecosystem	

(government	application	areas,	activities	at	other	levels	of	government,	industry,	the	

“crowd”).

• The	Circular	needs	to	better	explain	the	NSDI	and	how	federal	resources	will	be	coordinated,	

managed,	and	prioritized	in	support	of	NSDI	as	one	of	the	many	stakeholders	not	the	sole	

proprietor.	

• The	current	A-16	is	tightly	organized	and	logical	in	structure.	The	next	iteration	should	be	

even	tighter,	crisper,	clear	in	direction,	and	focused	on	action.	The	document	should	be	

designed	so	it	can	be	presented	as	a	digital	document	(hypertext,	as	opposed	to	traditional	

white	paper)	offering	an	overview	that	can	be	expanded	into	additional	levels	of	detail.

• The	concept	of	a	'Clearinghouse'	should	be	adapted	to	describe	the	current	and	future	

capabilities	offered	by	the	Geoplatform,	including	registering	distributed	data	services	

designed	for	enterprise	use,	2-way	communication,	and	workflow	tracking	between	users	and	

stewards	on	data	issues.

• The	document	references	NSDI	support	for	the	building	of	a	Global	Spatial	Data	Infrastructure	

(GSDI),	consistent	with	national	security,	national	defense,	national	intelligence,	and	

international	trade	requirements.	Reference	to	a	GSDI	could	create	confusion	and	needs	

further	explanation.	A	well-designed	NSDI	should	be	the	focus	and	will	in	all	likelihood	

translate	well	to	meet	nation-level	contributions	of	a	GSDI.

• More	attention	needs	to	be	paid	to	the	importance	and	practicality	of	metadata	within	the	

document.	Note	that	for	many	people	location	is	"metadata"	when	in	reality	it	is	much	more.

• The	document	frequently	uses	the	term	‘partnerships’	which	may	create	confusion,	

particularly	in	a	formal	or	legal	context.	We	suggest	acknowledging	that	with	current	

technology	every	organization	is	a	potential	spatial	data	collector	and	user,	often	

simultaneously,	and	the	goal	of	the	NSDI	is	to	organize	funding	and	work	processes	to	

leverage	this	most	effectively.
NGAC	Policy	Framework	Paper

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National	Geospatial	Advisory	Committee	(www.fgdc.gov/ngac) 6

• The	document	references	that	‘the	NSDI	assures	that	spatial	data	from	multiple	sources	

(federal,	state,	local,	and	tribal	governments,	academia,	and	the	private	sector)	are	available	

and	easily	integrated	to	enhance	the	understanding	of	our	physical	and	cultural	world.’	

However,	it	falls	short	in	describing	the	roles	of	any	organization	or	sector	other	than	federal	

government	agencies.	It	must	clarify	how	other	entities	contribute	and	participate.	More	

detail	should	be	offered	on	how	to	leverage	the	capabilities	and	resources	of	the	non-federal	

community	to	maximize	the	value	of	cooperation	and	coordination	in	the	collection,	

production,	sharing	and	use	of	spatial	information,	the	implementation	of	the	NSDI,	and	the	

identification	of	proven	practices.	The	‘Requirements’	section	could	detail	the	requirements	

for	partners	that	contribute	to	the	NSDI.

• While	implementation	of	the	Circular	is	essential	to	help	federal	agencies	build	the	best,	most	

accessible	information	resources	possible	in	a	cost-efficient	manner,	it	should	also	state	that	

this	is	the	means	to	achieve	a	more	fundamental	goal	and	public	benefit:	to	unleash	the	

tremendous	societal,	governmental	and	economic	benefits	of	a	location-enabled	society.

• The	document	references	that	the	FGDC	will	establish	procedures	and	committee	structures	

as	are	necessary.	This	is,	however,	a	federal-based	approach	to	address	a	"national"	issue.		A	

national	approach	would	be	best	to	solve	a	national	issue.

• Definitions	should	be	easy	to	find,	and	not	relegated	to	Appendix	D.	Typically	definitions	are	

offered	up	front	or	at	the	very	end	or	may	be	embedded	hover/hyperlinks	in	a	digital	product.	

The	definitions	also	need	to	up	updated	based	on	the	final	content	of	the	document,	which	is	

likely	to	reference	"crowdsourcing"	and	the	"cloud".

• The	document	would	benefit	from	modern	publishing	capabilities	that	embed links	to	maps,	

videos,	and	more	in	the	way	of	examples.	The	current	document	is	flat	and	does	not	represent	

the	visual	nature	of	the	technological	and	communications	resources	that	it	promotes.

• The	‘Does	this	Circular	apply	to	my	agency?’	section	should	be	thoroughly	rewritten;	this	

Circular	should	apply	to	every	agency	in	some	form.

• ‘Agency	Responsibilities	and	Reporting	Requirements’	should	align	with	the	supplemental	

guidance.

• ‘What	is	the	Federal	Geographic	Data	Committee	(FGDC)?’	and	‘What	are	the	benefits	of	the	

NSDI?’	should	be	combined	with	the	introduction,	background	and	purpose.

• ‘What	are	the	components	of	the	NSDI?’	should	be	bulleted	and	made	as	concise	as	possible	

and	should	reference	the	appendix	for	additional	detail.

• Add	an	executive	summary	to	draw	readers	in	and	trim	material	throughout	to	make	it	more	

concise	without	losing	significant	content.	Consider	what	level	of	detail	is	appropriate	for	

current	audiences	who	have	a	better	understanding	of	spatial	technology	than	those	in	2002.	

• Consider	a	stronger	directive	rather	than	a	minimal	compliance	checklist.

• A	number	of	specific	references	need	to	be	updated;	e.g.,	LRS	(satellite	resolution	issues).

• All	of	the	Appendices	will	require	updates.

3.		What	is	no	longer	relevant	or	should	be	removed?

• Many	of	the	terms	are	no	longer	relevant.

• The	Circular	doesn’t	adequately	reflect	the	current	geospatial	landscape	or	the	Federal	

geospatial	players.
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4.		What	is	missing?	What	are	the	gaps	or	additions	needed?

• Make	the	document	more	thorough	and	inclusive	by	expanding	the	list	of	participants	and	

their	corresponding	roles	beyond	the	federal	agencies.	

• Incorporate	geospatial	consumers	into	the	governance	rather	than	just	relying	on	geospatial	

information	(data)	producers.

• Include	a	plan	for	future	document	updates.

• Describe	how	new	technologies/new	applications	should	be	handled	between	updates	in	the	

Circular.

• Consider	incorporating	material	from	NGAC’s	Transition	Recommendations	paper	to	reinforce	

consistent	messages.	This	document	should	reiterate	the	value	proposition	for	geospatial	

investment,	and	then	provide	a	framework	for	doing	it	better	with	the	NSDI.

• Acknowledge	crowdsourcing	and	citizen	science	as	new	channels	for	data	development	and	

public	engagement.

• Provide	examples	to	illustrate	concepts	and	demonstrate	potential	for	success.

• Reference	existing	public	law	and	gaps.

• Reference	more	existing	policies	and	include	examples	of	policies	from	other	countries.

• Clearly	articulate	why	it	is	relevant	to	the	greater	geospatial	community	rather	than	just	

federal	agencies.	Language	from	the	Supplemental	Guidance	may	be	useful.

• Reference	related	policies	and	Presidential	Directives	- such	as	National	Open	Data	- where	

appropriate.

• Consider	addressing	privacy	within	the	realm	of	what	is	appropriate	with	respect	to	OMB	

guidance	and	FGDC	guidelines.

• Acknowledge	that	geography	is	inherently	local.	For	many	of	the	most	important	geospatial	

information	resources,	local	government	is	constructing	the	most-detailed,	best	quality,	and	

most	current	data.	This	makes	sense	at	local	government	is	‘closest’	to	geography	that	is	

changing	and	therein,	able	to	connect	to	change	processes	and	to	verify	reported	changes.	

Federal	agencies	should	be	required	to	align	their	business	processes	to,	where	appropriate	

(and,	where	individual	states	are	willing),	source	geospatial	data	from	local	government	and	

aggregate	this	information	at	the	state	level.	Many	federal	programs	predicated	on	

connecting	with	local	communities	are	administered	through	states	through	block	grant	

programs;	this	is	also	a	model	for	services	and	information	products	related	to	local	

geography.