GPO’s new Regional Discard Policy and GPO’s recent presentations about it are full of hopeful words and good intentions. We applaud GPO for having good intentions and high hopes, but we question if the Policy can meet those expectations.
- Introduction of the Policy and its Implementation
- One definite Goal. Some questionable objectives
- Preservation of and Access to Paper Copies
- Next steps
Here is what you need to know about the Discard Policy. GPO’s caveats and assurances about the new policy aside, there will no longer be any Regional Depositories for documents more than seven years old. It removes the requirement that there be access paper copies of all documents in the FDLP. It weakens the FDL Program by continuing the shift of responsibility away from FDLP members and toward GPO. It does not increase flexibility (as advocates of the policy claim), it shifts flexibility away from Selectives and gives it to Regionals. It puts new burdens on Selective Depositories. It establishes a new model for the preservation of paper copies of documents that is undocumented, unproven, and risky. It ignores long-term implications in favor of short-term benefits to a few large libraries. It makes GPO’s “guarantee” of long-term, free access to government information nothing more than a hollow promise.
We believe that the Policy actually weakens the FDLP and damages both access and preservation. We believe that the Policy provides no guarantee of meeting those expectations, and will make it more difficult to do so. Below, we explain why.
At the Fall Depository Library Council (DLC) meeting, GPO gave a general outline of how it will proceed to allow Regional Depository Libraries to start discarding paper copy documents.1 GPO has, so far, provided the following information about the Policy itself and how GPO intends to implement the policy:
- Government Publications Authorized for Discard by Regional Depository Libraries [draft policy, 07/09/2014]
- Vance-Cooks, Davita. [letter (July 10, 2015) from GPO to Gregg Harper, Chairman Joint Committee on Printing (JCP) requesting approval of policy to give regional Federal depository libraries the option to withdraw tangible depository materials]. and Harper, Gregg. [letter (August 5, 2015) to GPO] Both documents in one PDF file here.
- Council Session on Discards audio recording and presentation slides (10/20/2015)
For additional background, links, and commentary, see: Information sharing and the National Plan by Shari Laster.
The new policy has only one stated goal: To allow regional depository libraries the option to discard paper copies of government documents.2. To be clear, this is not a substitution of one format for another, like microfiche for paper. Regionals will not be required to uphold their Title 44 obligations to “retain at least one copy of all Government publications either in printed or microfacsimile form.” (44 U.S.C. §1912).
In addition to this specific goal, GPO has expressed a variety of objectives, which it apparently hopes the new policy will help accomplish. But GPO has been both inconsistent and vague in its expression of these objectives and how it will actually implement the policy.3 Six Regional Depositories will participate in a test of the policy in early 2016; presumably, this will produce more implementation details.
Some of GPO’s objectives (such as giving Regionals “the ability to expand their capability to serve the increasing number of remote users” [Vance-Cooks]) can be accomplished without the new policy.
Most of the objectives relate to giving Regionals the “flexibility” to discard paper copies of documents. GPO does not claim that this will have any positive effect for users. On the contrary, GPO acknowledges that regionals that are already relocating tangible collections to offsite storage are impairing the goals of the FDLP.4 GPO implies that Regionals will use resources that will be freed by discarding documents “to focus on the needs” of users of government information [Vance-Cooks]. But GPO does not specify what the resources are, or explain how it expects freed space to be reallocated to services or collections for users of government information, or require any such reallocation. Furthermore, some Regionals have admitted that any savings brought on by this policy will not go toward public service of government information, but will go toward their library’s central operating budget. Since the Policy does nothing to further such objectives, we should not read them as objectives of the Policy but as wishes of GPO.
As FGI readers will know, OMB has asked the public for comments and suggestions to revise its Circular A-130 “Managing Information as a Strategic Resource.” Interestingly, they have chosen to manage the commenting process on http://github.com, the collaborative software versioning and management site.
We at FGI have submitted a comment (or “issue” in GitHub parlance) at: https://github.com/ombegov/a130/issues/65. We could really use readers’ help in raising awareness of library issues at OMB and in their A-130 policy to executive agencies. Please go to GitHub and leave a comment or additional suggestion on that issue. The more comments an issue gets, the more likely that OMB will take the suggestion seriously. You can also add your own suggestions/issues [see instructions at https://a130.cio.gov].
We the FGI editors thank you for your assistance!
OMB’s Circular A-130 “Managing Information as a Strategic Resource” — along with the 1980 Paperwork Reduction Act (PRA) 94 Stat. 2812, which “establishes a broad mandate for agencies to perform their information resources management activities in an efficient, effective, and economical manner” – do not directly address and therefore have had unintended negative consequences for long-term access to and preservation of Federal government information.
These policies, along with agency practices of using the web for distribution without attending to consistent standards or to preservation, have resulted in the creation of many incompatible, inconsistent, often badly indexed and difficult to use agency web sites and a propagation of “deep Web” .gov databases. This not only makes it more difficult for individuals to find and use the government information they need, it also makes it difficult for institutions to identify, acquire, describe, and preserve agency “publication information” (defined in draft A-130 line 1066) for the long-term. Such institutions include the Government Publishing Office (GPO), libraries in the Federal Depository Library Program (FDLP), the Internet Archive, and institutions (like Sunlight Foundation, the Government Accountability Project and Open The Government) that promote open-government and government transparency.
Draft A-130 mentions “threats” on page 1, but does not mention the threat of loss of information because of insufficient preservation actions. We recommend therefore that A-130 be updated to require that all government agencies facilitate preservation of and long-term free public access to their publications. This would put the same requirement onto information produced at government expense by government agencies that the National Science Foundation (NSF) and other government funding agencies put onto the data produced by government funded research.
Every government agency should be required to have an “Information Management Plan” for the public information it acquires, assembles, creates, and disseminates. The Information Management Plan should specify how the agency’s public information will be preserved for long-term, free public access and use including its deposit in a reputable, trusted, government or non-government digital repository (including, but not limited to GPO’s FDsys). All executive agencies should deposit their publications in FDsys.gov and their data in data.gov.
As one aspect of implementation of the Information Management Plan, we recommend that every government agency be required to make its own website compatible with a few basic, consistent requirements to make it easier for the public to discover, acquire and use its information. Each agency’s site – including subdomains – should be required to:
1) Follow Web standards and design their sites with site maps. All agency sites should be Archive ready (http://archiveready.com);
2) Use a standardized directory structure that identifies major types of information (e.g., ../publications ../data ../video ../blog ../podcast ../pressreleases ../rss etc);
3) Have permanent urls in the form of DOIs or some other standard for all agency publications and other information products.
Updating A-130 for the 21st century to take full advantage of the Internet will bring executive agencies in line with the White House’s Open Government Initiative, will facilitate public access, will require the preservation of agency publications, and will facilitate economic efficiency by encouraging centralized digital preservation while allowing for the use and expansion of non-government digital repositories.
James A. Jacobs and James R. Jacobs
Free Government Information
[UPDATE 11/20/15: OMB has extended the commenting period for 15 days until December 5, 2015. JRJ]
Office of Management and Budget’s Circular A-130 Managing Information as a Strategic Resource — along with the 1980 Paperwork Reduction Act (PRA) 94 Stat. 2812, which “establishes a broad mandate for agencies to perform their information resources management activities in an efficient, effective, and economical manner” — has had a *huge* negative impact on the work of libraries and the Federal Depository Library Program (FDLP), and has had many unintended consequences for access to and preservation of Federal government information. It has made GPO’s work in maintaining the national bibliography much harder because A-130 and PRA have given Executive agencies broad leeway in publishing their information without regard for Title 44, GPO, and description and distribution of FDLP materials to libraries.
But now, OMB has requested comment on A-130 — via GitHub no less! — which hasn’t been updated since 2000. So here’s a chance for depository librarians and others to let OMB know how they can edit A-130 in order to assure free public access to — and most importantly preservation of! — federal government information and help libraries and librarians across the country deliver access and services to their communities.
We outlined some of FDLP’s needs in our 2010 Letter to Deputy CTO Noveck: “Open Government Publications” and in other places. Basically, we need executive agencies to work with GPO in creating and maintaining the national bibliography. We need executive agencies to create and follow Web standards and design their sites to make it easier for the GPO and FDLP to do their jobs — and by extension make it easier for the public to access federal information. For example, each agency should have ../publications and ../data directories (and others like ../video etc) on their sites, all of their publications should have permanent urls in the form of DOIs or some other standard, agencies should deposit their publications in FDsys.gov and their data in data.gov.
Please consider submitting comments so that the FDLP can have a federal information policy that helps libraries and GPO do their jobs.
The White House Office of Management and Budget (OMB) is proposing for the first time in fifteen years revisions to the Federal Government’s governing document establishing policies for the management of Federal information resources: Circular No. A-130, Managing Information as a Strategic Resource. More specifically, Circular A-130 provides general policy for the planning, budgeting, governance, acquisition, and management of Federal information resources. It also includes appendices outlining agency responsibilities for managing information, supporting use of electronic transactions, and protecting Federal information resources.
The proposed revisions to the Circular are the result of new statutory requirements and enhanced technological capabilities since the last update to the Circular in 2000. Modernizing this policy will enable OMB to provide timely and relevant guidance to agencies and will ensure that the Federal IT ecosystem operates more securely and more efficiently while saving tax dollars and serving the needs of the American people.
The proposed Circular reflects a rapidly evolving digital economy, where more than ever, individuals, groups, and organizations rely on information technology to carry out a wide range of missions and business functions. Information technology changes rapidly and the Federal workforce managing IT must have the flexibility to address known and emerging threats while implementing continuous improvements. This update acknowledges the pace of change and the need to increase capabilities provided by 21st century technology while recognizing the need for strong governance and safeguarding of taxpayer funded assets and information.
The proposed guidance is now open for public comment on this page. The public feedback period will be 30 days, closing on November 20, 2015. Following the public feedback period, OMB will analyze all submitted feedback and revise the policy as necessary.
(Background here: http://freegovinfo.info/node/10285)
At the 2015 Depository Library Council meeting on October 20th, Mary Alice Baish, Superintendent of Documents, informed the depository library community that in July, GPO had formally requested permission from the Joint Committee on Printing (JCP) to allow Regionals to discard documents in tangible formats that have been retained for seven years when an authenticated, digitally signed version is available on FDsys. The response GPO received in early August approved this request, setting the additional condition that a minimum of four physical copies of each document be maintained within the FDLP, and suggesting the use of existing Census regions to ensure the geographic dispersal of these copies.
According to GPO’s presentation, the process for approving the withdrawal of tangible items at Regionals and identifying the geographically dispersed copies retained in tangible format will be conducted for the time being based on GPO’s ten existing print procurement regions. Six libraries have been identified to pilot the process, and GPO staff will work with these institutions to begin withdrawing materials in January 2016.
The presentation was webcast live and is available as a recording; the Regionals meeting later in the evening was also webcast live and is also available. Following the conference, GPO released the letter from GPO Director Davita Vance-Cooks, and the reply from Congressman Gregg Harper, Chairman of the Joint Committee on Printing. No final version of the policy has been made available at this time.
It is clear that GPO has listened to the community to some extent: the presentation identifies specific GPO activities that address community concerns including seeking trusted repository certification for FDsys and prioritizing bibliographic control projects for the national collection. Still, the available documentation suggests that there has been very little information shared between GPO’s request for feedback and discussion in April 2014 and the announcement of the policy’s implementation in October 2015, other than a request for information regarding intent to discard from Regionals.
Setting aside the wisdom of identifying a minimum number of tangible copies, let alone such a low number, and also setting aside the question of how preservation and access copies will be identified and maintained, this project represents a pattern in how FDLP initiatives are discussed and documented.
At the same DLC meeting, the FIPNet update was a lively discussion of various collaborative projects undertaken by individual libraries and library consortia. The second part of the program featured a presentation from Dr. Katherine Skinner, Executive Director of the Educopia Institute, on the value of collective action, which is a key element motivating any project that must be carried out on a widely distributed basis. Both recordings are linked below.
While the variety of approaches to preserving government information is laudable, only the University of North Texas has signed a formal FIPNet partnership agreement. To the best of my knowledge, no other organization has formally announced its intent to join FIPNet yet. Anecdotally, it seems that at least some potential partners are waiting to see what a partnership would entail, prior to committing. There are two opposing forces at play: on the one hand, GPO has stated its intention to be flexible and open to partnership opportunities, which precludes providing structured articulations of what FIPNet participation entails. But the lack of documentation and specifics makes it more difficult for potential partners to identify the roles or responsibilities they wish to take. While I hope there are a substantial number of closed-door discussions between GPO and potential partners, we have no way to know.
Both FIPNet and the implementation of the Regionals discard policy are part of the National Plan. But the Plan itself is not a plan: instead, it is a strategy outlined in presentations, with a few key diagrams available in handouts and slides posted on the website. In my experience, community members are still asking each other “Where is the National Plan? What is FIPNet? Is it here yet?”
We’re all in uncharted waters here, but the community outside of the Depository Library Council (DLC) is at a particular disadvantage. It’s understandable that GPO leadership would be cautious in formal public commitment to specifics for programs that are under development, especially a program like FIPNet, which has few existing precedents. However, when the only detailed documentation for a project or initiative are recorded conference sessions, it is hard to both believe and persuade others that this is a fixed course of action for GPO.
It is vital for the depository library community to understand projects and initiatives to communicate about them with library administrations and those working outside of government documents. Still, many (and perhaps most) depository librarians are simply not sure how to explain the National Plan or FIPNet. Without a formal guiding document, anyone trying to understand these developments must wade through a maze of recorded presentations and handouts. Even clearly-labeled draft or discussion documents would be an improvement in access to this information.
I have an enormous amount of respect for all of the work that Library Services & Content Management (LSCM) does on behalf of the FDLP: this office has some of the hardest-working, most dedicated librarians I’ve had the fortune to meet, and asking for more documentation means more time spent writing, editing, approving, and publishing documents that will become outdated as the systems develop and progress. Still, it is the documentary trail that we need to rely on for our shared understanding of where the FDLP is, and where it is going. Otherwise, we are doing the best we can by word of mouth alone — and that may not be enough.
Martin Halbert et al. “FIPNet and Stratigies for Utilizing the Collective Impact Model.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated 19 October 2015.
Federal Depository Library Program. “Regional Meeting.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 20, 2015.
Library Services & Content Management. “Implementing the National Plan: Focusing on Users and Services.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 19, 2015.
Library Services & Content Management. “New Regional Depository Library Discard Policy.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 20, 2015.
Library Services & Content Management. “JCP Approves Regional Discard Policy.” http://www.fdlp.gov/news-and-events/2403-jcp-approves-regional-discard-policy. Updated October 22, 2015.
Katherine Skinner. “From Collaborative Action to Collective Impact.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 19, 2015.
- On Veterans Day, VA Quietly Unveils New ‘Vets.gov’, By Mohana Ravindranath NextGov (November 11, 2015).
Currently, the site is a bare-bones framework of that vision.
Within the next year, veterans will be able to manage all their personal information in one account on Vets.gov, VA Secretary Robert McDonald said in a statement on the site.