As we wrote a month ago, the White House guidance on open government asked the right questions for federal agencies to answer. Commendably, some agencies are already moving to post drafts of their plans for public discussion in advance of the Sept. 15 deadline to post their next Open Government Plan online on their open web pages, including the Social Security Administration and the Department of State.

Sunlight applauds these agencies for sharing drafts for feedback online and strongly encourage all of them to do so as soon as possible. We also, however, have concerns about the State Department’s exclusive use of TechChange’s GovUp platform for public feedback, and we have shared that on the White House open government discussion group.

UPDATE: As Tim Bonnemann pointed out in the open government listserv, the agency’s draft of the U.S. State Department 2016 Open Government Plan is available online at a public URL with no registration requirement, as a view-only Google Doc.

That’s good news. While most online platforms require registration for use in 2016 – from social media to the MADISON software the General Services Administration used for feedback on the U.S. Public Participation Playbook – the public should not have to provide a federal agency with additional personal information in order to provide feedback on an open government initiative.

We’ve preserved the initial version on our server, which you can download as a PDF to a computer or mobile device, but it will be out of date if and when State makes any changes to it.

At minimum, we strongly recommend that all agencies post their open government plan online as a web page — in HTML, not a PDF, just as the 2014 plan is currently available — and take public comment on it through print, phone, email and social media channels without licensing, privacy or copyright constraints. Agencies should also consider publishing a draft on MADISON and Genius to offer the public more opportunities to directly annotate sections. We’ve asked the State Department to expand its public engagement efforts in this direction and to turn on the ability for the public to add annotations to the Google Document.

UPDATE: If you have feedback on the agency’s plan and do not wish to use GovUp to share it publicly, the State Department has created OpenGovPlan@state.gov in response to Sunlight’s comments. André Goodfriend, senior advisor in the Office of eDiplomacy, will be reviewing the incoming comments and welcome the public’s feedback. Alternatively, you can send a letter to the State Department’s Bureau of Information Resource Management, 2201 C Street NW, Washington, D.C. 20520. We will be submitting our own feedback directly and will share it here as a followup post.