Although it may be tempting to believe that new standards will subsume older ones, thereby making it possible to translate documents in older standard forms into newer standard forms without losing much, this belief has proven itself untenable, for example, when paradigm shifts change our conception of our documents so radically that translation becomes meaningless. But relying on standards for long-term preservation of digital material appears to its critics as unwise. There will be many instances in which the use of standards cannot eliminate the dependence of digital documents on the software that created them. Whatever its degree of reliance on standards, migration involves translation. Moreover, the translation demanded for each format and type of document will be different, requiring unique handling for a large number of distinct cases, in cycles that are inherently unsynchronized.
Migration is therefore highly labor-intensive.
Yet, in Rothenberg's view, that is far from its worst problem. He believes its fatal flaw is that it is impossible to predict what it will involve in the future. Since it is not known when any format, standard, document type, or class of software will become obsolete or what new format, paradigm, or program will replace it, it is impossible to say what will be required to migrate a given document, let alone how this will be accomplished, how much effort will be involved, or how much will be lost in the translation process. If a document is accepted for long-term storage based on an assumed migration strategy, it is impossible to give even gross estimates of what will have to be done to it in the future, when this will have to be done, how much it will cost, or how long it will be before the document is corrupted by inappropriate translation. That said, it is still a fact that the strategy of data migration is in effect nearly everywhere.