NGAC Initial Comments on Geospatial Data Act Implementation – May 2019 1

National Geospatial Advisory Committee

May 2019

Initial Comments on Geospatial Data Act Implementation

The National Geospatial Advisory Committee (NGAC) convened a sub-group to review the initial 

analysis of the Federal Geographic Data Committee (FGDC) Geospatial Data Act (GDA) Tiger 

Team. The Tiger Team held its first meeting November 14-15, 2018. The NGAC’s initial 

comments are organized into a general section followed by specific comments related to the 

different parts of the law that impact the Federal Geographic Data Committee (FGDC) and the 

NGAC, as well as feedback on the Tiger Team’s initial assessment of each section. This paper 

references the FGDC Tiger Team’s initial analysis of the GDA, which is posted at: 

https://www.fgdc.gov/gda/fgdc-gda-tiger-team. 

1. General Comments

● The GDA focuses on solidifying the present situation with respect to the National Spatial 

Data Infrastructure (NSDI). It is critical that the FGDC and member agencies look to the 

future, encouraging modern practices and up-to-date technologies. Refer to the NGAC 

report: Emerging Technologies and the Geospatial Landscape (2016). 

● The NGAC encourages the Tiger Team to review and recommend the use of papers and 

recommendations produced by the NGAC to inform the FGDC and agencies on best 

practices and to provide insights on future directions for geospatial services and 

technologies. These papers will be referenced when relevant in this document. All 

NGAC papers are posted at: www.fgdc.gov/ngac.

● GDA implementation will require additional Secretariat support for the FGDC, as well as 

more information management from the covered agencies. FGDC will need appropriate 

resources to successfully implement the requirements of the GDA.

● Consider what the implications are that the goals of the NSDI are no longer derived from 

consensus among the drafters of the strategic plan, but are vested in legislative 

language. 

● When implementing the GDA, the Tiger Team and the FGDC should also consider 

overlapping or complementary requirements of the Foundations for Evidence-Based 

Policymaking Act (H.R. 4174), which includes the OPEN Government Data Act (H.R. 

4174). The 21st Century IDEA Act (H.R. 5759) may also have some relevance and should 

be reviewed. 

2. Governance/Organization (Secs 752, 753, 754)

Language of the act itself

● 752 (3) The list of covered agencies now excludes some current FGDC members.

● 752 (5) The “geospatial data” definition may need clarification. It is important for the 

Tiger Team to be aware of and think about the implications of indirectly identifiable 

data and crowdsourced data.
NGAC Initial Comments on Geospatial Data Act Implementation – May 2019 2

● 753 (B)(2)(A) and (B) Given the organizational level of an FGDC “appointment,” what 

should be the organizational level of the covered agency’s designated representative? 

The status of a position can sometimes exert undue influence so the intent should be to 

have comparable peer levels of participation. 

● 753 (C)(4) This will require some level of self-reporting for member agencies. How will 

objectivity be ensured?

● 753 (C)(7)(C) The examples are at the Federal level. What is included under “non-Federal 

resources”?

● 753 (C)(8) How will the FGDC ensure meaningful input from those identified in this 

section but who do not have representation on the Committee? 

● 753 (C)(11) and (12) This review process could be challenging for the NGAC as it will 

impact their ability to do other committee work, unless the approaches to (11) and (12) 

are well streamlined. 

● 754 (B)(1)(C) This section lists sectors/communities/organizations that include a variety 

of types of geospatial professionals (i-x and xii), whereas xi calls out a specific group of 

geospatial professionals (who are presumably already included in i-x and xii). This 

makes the composition of this list somewhat inconsistent. However, if the list is going 

in this direction, perhaps it should include a call-out of Certified geospatial professionals 

(certified by any of the credentialing organization providing geospatial -related 

certification--GISCI, ASPRS, USGIF, etc.)

● 754 (B)(4)(A) This section does not include any mention of standing subcommittees. 

The FGDC should consider term limits for non-NGAC members.

● 754 (F)(2)(A) The FGDC should consider an appropriate time by which the request for 

information should be answered. Unless timelines exist it might be hard to claim lack of 

cooperation in a meaningful way.

● 754 (F)(2)(A) A process should be put in place to codify how the requests for information 

are made and approved. 

Workshop and Tiger Team Assessment Comments

● The NGAC agrees with the following comments:

○ Observation of the elevation of membership of FGDC and the need to 

determine the impact of this provision.

○ Recognition of the expanded workload is important.

○ Agencies that are currently not listed as covered agencies should be kept 

on the FGDC.

○ Automation of the reporting process is potentially a good idea. The Tiger 

Team should study if there is a template that can be used for all of the 

agencies or if each is specific enough that it needs its own reporting 

mechanism. The GeoPlatform Performance Dashboard may be a good 

starting point for discussion in terms of expansion or as a model. 
NGAC Initial Comments on Geospatial Data Act Implementation – May 2019 3

● General comments:

○ The NGAC charter will need to be redone. The FGDC should look for 

current models or best practices of other statutory Federal advisory 

committees by reviewing documentation from the DOI or the GSA. 

○ The FGDC and the NGAC should seek input on the charter revisions from 

the stakeholder partner community as a means of engaging the partners 

in this new process. This should be done following legal guidance on the 

FACA rules governing this area.

○ The process by which the NGAC makes its decisions should be carefully 

considered and described so that all partners have an equal voice.

○ Look to ways to make the governance structures collaborative in order to 

keep the right people and groups engaged.

○ Identifying spending on geospatial data is difficult because accounting 

and budgeting systems are not designed to track this information. Given 

that, it is critical to accurately account for this spending in order to get 

sufficient budgetary support from Congress. A successful national 

geospatial effort will take significant, coordinated investment.

○ It is important to ensure that covered agencies understand reporting 

specifics and that there is agreement on definition of terms.

3. Data, Standards, and Delivery (Secs 755,756, 757, 758) 

Language of the act itself

● 755 (A) Responsibility for ensuring integration from multiple sources, often with their

own jurisdictional authority, will not be trivial.

● 755 (B)(1)(C) This section discusses “free and open access for the public to geospatial 

data, information, and interpretive products, in accordance with Office of Management 

and Budget Circular A–130.” “Free and open access” is not mentioned in A-130 

although “access” and “accessibility” are noted.

● 755 (D) With what authority and effectiveness can the FGDC influence non-Federal users

attention to their “responsibilities”?

● 756 (General) The call for dissemination of data through the geoplatform and usability 

of that data should encourage the use of services as articulated in the NGAC Geospatial 

Data as a Service white paper. 

● 756 (A)(2)(B) What does “used in common” mean in this context? 

● 756 (B) This section references meeting the needs of the users, following a common 

pattern in government of taking a more user centric approach. The FGDC should be 

encouraged to take a user or mission view of data theme priorities, such as cross-cutting 

challenges like disasters or infrastructure renewal rather than a strictly data-focused 

view.

● 758 (General) Do the provisions here in any way limit how the platform may adapt to 

future available/desirable technologies and data sources? Note that the NGAC 

members reviewed the GeoPlatform and provided comments, which are covered in the 

NGAC GeoPlatform Feedback Summary from June 2018.
NGAC Initial Comments on Geospatial Data Act Implementation – May 2019 4

● 758 (B)(1)(A)(iii) Data and metadata “indirectly” collected may be a challenge and, 

perhaps, not fully obtainable. Does this appear to be a requirement?

Workshop and Tiger Team Assessment Comments

● The NGAC agrees with the following comments:

○ Wise acknowledgment of the growth of lead covered agency responsibilities with 

the need for resource authorization.

○ We understand the comment about streamlining and minimizing reporting 

processes to leave more time to work on data, but reporting and showing results 

are crucial to gain support and funding. There must be a balance.

○ Good comments about the need to coordinate and develop best practices for 

standards across agencies and multiple standards bodies. See the NGAC paper: 

Geospatial Standards: A National Asset.

○ We agree with the need to specify metadata requirements that apply to all 

geospatial data.

● General comments:

○ The definition of ‘authoritative’ is critical, but won’t be easy to achieve. Please 

refer to page 6 of the NGAC Geospatial Data as a Service white paper.

o There is an assumption that the NSDI is going to be developed in partnership 

with other levels of government, academia, tribes, and the private sector. When 

creating standards, they must be useful and useable by all. This has not always 

been the case, such as with cadastral. 

o Note that two NGAC papers may be useful to the Tiger Team: Comments on 

OMB Circular A-16 and the Geospatial Policy Framework and the Comments on 

the National Geospatial Data Asset (NGDA) Portfolio Management Process.

4. Covered Agencies/Reporting (Secs 759, 759A) 

 Language of the act itself

● 759 (A)(2)/(3) The words “share” and “integration” are innocuous but the 

implementation of the tools and applications needed can be costly. Will the strategic 

plan mentioned for the NSDI be able to address resource needs? Section 759 (A)(5) 

mentions “allocate resources to fulfill the responsibilities” but there is lack of evidence 

that the federal agencies have sufficient budget flexibility to meet this requirement.

● 759 (B)(3) Disclosure and posting information about transactions is still simply data. 

How would that be used as information or knowledge in some decision process about 

related transactions? Do the two cited .gov sites have sufficient rigor to support such 

analysis?

Workshop and Tiger Team Assessment Comments

● The Tiger Team recognizes the need for a coordinated budget request for FY21.

● Comments note that there needs to be “a central place where metadata for state data 

resources are cataloged.” Consider discussing with NSGIC as they have discussion 

underway as to how to do this properly.
NGAC Initial Comments on Geospatial Data Act Implementation – May 2019 5

● The identification of “geospatial” relevance to specific transactions by creating some 

“tag” is insightful but who might have the authority to do that? Who will establish the 

criteria without ambivalence?

● “Where will resources come from?” is the critical question. The objectives may all be 

desirable but none can be achieved without sufficient resources. Will each agency need 

to decide what will be swapped out to address this law? Are there penalties for noncompliance?

5. Communication/Outreach 

General comments

● Every upcoming geospatially-related conference for 2019 and 2020 should have a 

presentation or a session of presentations to explaining the new law and its potential 

impacts. 

● There will be a big education challenge to make sure agencies understand what their 

new responsibilities are and how to meet them. Consider creating outreach materials 

such as a YouTube video to explain what has and has not changed, the implications for 

the agencies, and the implications for the geospatial data producers and users.

● A key role for the geospatial community, and particularly for outside stakeholder 

partners and professional and trade associations (such as COGO), is to advocate for 

additional resources for the NSDI. Advocacy requires a coordinated plan with relevant 

communication materials to be effective. Consider collaborating with groups such as 

COGO who might be able to lead in development of a plan, creation of the materials, 

and coordination of the necessary outreach.

● It will be important to begin educating and familiarizing Congressional members on the 

progress and successes of creating, disseminating, and applying geospatial data to meet 

government mission needs well in advance of the first reporting requirement. Early 

engagement will build support and a receptive audience for future requests of support. 

The geospatial community should consider organizing a “GIS on the Hill” event to help 

educate Congressional members and staff.

● While addressing the specific requirement of reporting, it’s important to look at the big 

picture and continue to showcase to Congress the successes and benefits of using, 

sharing, and applying geospatial data.

● We recommend that the FGDC and NGAC should put together an outreach, 

communication, and engagement materials for stakeholder partners including those in 

both the geospatial data provider community and the broader community of data and 

app consumers (non-geospatial experts).

NOTE – This paper was prepared by an NGAC team that included the following members: Julie 

Sweetkind-Singer (Chair), Pat Cummens, Roberta Lenczowski, Cy Smith, Rebecca Somers, and Jennie Stapp.