Not every missing public record was deleted. Sometimes it fell between two databases.
That distinction is less dramatic than a purge and often more useful. Government systems are replaced for the same reasons any large information system is replaced: aging software, rising maintenance costs, security requirements, vendor changes, new workflows, and years of customizations that have turned the original design into something nobody particularly wants to touch anymore.
The danger appears during migration. A new system may not have the same fields, identifiers, attachments, search behavior, or public interface as the old one. Data can survive internally while becoming much harder for the public to locate.
The 2023 retirement of FOIAonline provides a documented example. FOIAonline had served as a shared Freedom of Information Act request and records platform for multiple federal agencies. EPA decided to decommission it on September 30, 2023, and participating agencies moved toward replacement case-management systems.
The National Archives’ Office of Government Information Services documented the transition in detail. Its FOIAonline decommissioning notice said partner-agency data would be migrated to replacement systems, while public access to the FOIAonline application itself would end on September 30, 2023. In a March briefing, EPA officials urged registered users to download data they wanted readily available and acknowledged that some agencies could experience temporary service gaps while open cases moved.
Migration changes more than storage
A public database is partly the records and partly the machinery for finding them.
Suppose the old system exposes request numbers, agency names, dates, dispositions, attachments, requester correspondence, and full-text search. A replacement might retain the official case record while exposing fewer fields publicly. Another system might import the metadata but not preserve old attachment URLs. Search filters can change. Stable identifiers can be replaced. Previously public material can require a different route to obtain.
None of that necessarily means the underlying record was intentionally destroyed.
FOIAonline makes the point neatly because the data and the public interface had different afterlives. A 2024 FOIA Advisory Committee discussion noted that FOIAonline had served as a centralized repository containing eleven years of released records and that public-interest groups had copied material before shutdown; MuckRock and the Project on Government Oversight preserved nearly 34,000 documents. Meanwhile, agencies migrated their own case data into separate replacement systems.
Compare before calling something lost
A careful investigation starts with exports or snapshots of the old system. Record counts can be compared. Fields can be mapped. Attachments can be sampled. Old identifiers can be searched in the replacement. Web archives can show what the public interface exposed before shutdown.
The result may reveal several categories rather than one: records successfully migrated, records retained but exposed through a different search interface, fields or identifiers that no longer map cleanly, attachments moved to new URLs, and genuinely missing material. EPA, for example, now says its replacement FOIAXpress reading room contains 1.8 million records previously released through FOIAonline. That is evidence of substantial continuity, not evidence that every old public record vanished.
That is less satisfying than a single accusation, but it is how information systems actually fail.
Database replacement can create access loss without anyone pressing a delete button. Sometimes the records migrate successfully while the old centralized search, identifiers, links, or context disappear. FOIAonline is useful precisely because its shutdown produced a mixed result rather than a melodramatic one: a dead public platform, migrated agency data, recreated repositories, and independently rescued documents.