During this week’s Open Government Partnership meeting in London, the Obama Administration announced the broad strokes of its National Action Plan 2.0 Freedom of Information Act reforms.

The Administration’s announced plan has several goals: the implementation of an online FOIA portal, drafting of a unified set of FOIA regulations, creation of an interagency working group and an advisory committee to improve FOIA processing, and improved FOIA trainings for agency employees.

While these plans do give the transparency community reason to be cautiously optimistic, it is important to note that there is no mention of proactive disclosure anywhere in the plan. Proactive disclosure is integral to any effective transparency plan. It meaningfully increases public access while easing the burden on FOIA processing by eliminating duplicative request processing.

As for the efficacy of the goals included in the NAP 2.0 plan, the new FOIA proposals could be very positive or could make things even more difficult for requesters - the devil really is in the details.