“…69 In a similar vein, Kluttig argues that functional analysis of records creators can be approached on a collaborative basis. 70 In order to cope with the appraisal challenges posed by increasing administrative complexity, the growth of importance of private records, and greater integration between government levels following reunification, a 2011 position paper from a Society of German Archivists Working Group advocated cooperation in appraisal between archival institutions in different levels of German government, echoing Booms's 1972 suggestion. 71 Sudmann extends the debate by suggesting that a cooperative approach to horizontal and vertical appraisal can be applied to important private records, such as those of NGOs.…”