The GPO’s Office of the Superintendent of Documents released its National Plan for Access to U.S. Government Information: A Framework for a User-centric Service Approach To Permanent Public Access in February. Our colleague Shari Laster has written a really thorough overview and background of the document, so we will use this post to analyze the Plan in more detail and suggest how it can (and should) be improved. In a follow-up piece, we’ll then move from strategic planning to an environmental scan and Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis of the current FDLP as it relates to the Plan, including more context of what’s in place and what we feel is missing in order to build a sustainable digital FDLP ecosystem.
The Plan has many good and useful suggestions and reflects a welcome and increasingly effective articulation by GPO of the importance of long-term preservation and free public access to government information. (We have not always had GPO administrations that accepted these basic values.1) Perhaps most importantly, the Plan reflects GPO’s most emphatic acknowledgement so far of the reality that it cannot achieve its long term goals alone — it needs “partners.” As a foundation for building a strategic plan that will guide GPO’s activities toward its most challenging long-term goals, the Plan articulates most of the underlying values needed for such an endeavor and enumerates many of the particular actions that need to be taken.
That is the good news. There are two pieces of the Plan that concern us though. First, the Plan is only a plan for GPO’s Library Services and Content Management (LSCM) unit — it is not a Plan for the FDLP. Second, it weakens its planning by using the five “Principles for Federal Government Information” as goals to achieve rather than as values to guide goal-making. This is a subtle point, but an important one and we will show how a small change in the Plan can improve it significantly.
Purpose and Focus of the Plan
The Plan is designed to guide one unit within GPO, not the FDLP.
The National Plan for Access to U.S. Government Information is a framework document that sets and supports the strategic direction of the Library Services and Content Management (LSCM) business unit of the U.S. Government Publishing Office (GPO). [p3]
By taking this approach, GPO fails to embrace its greatest, oldest strength: its more than one thousand institutional partners. It is puzzlingly odd that GPO thinks that prolonging its policies that shift responsibilities for preservation and access of FDLP content from depository libraries to GPO will work when, at the same time, it explicitly acknowledges that “No one library or institution can do all that is required to preserve the entire corpus of Government information” [p7].
Of course, the Plan does not ignore FDLP. GPO views FDLP as one of its many “obligations,” saying that the Plan will “help to fulfill the statutory mandates of the Federal Depository Library Program.”
GPO’s focus on the Program as an obligation means that only one of its “Strategic Priorities” even acknowledges FDLP and that objective is about the “Governance and structure of the FDLP” [p8]. That Priority includes GPO’s role in the management of the “resources” of depository libraries, but the detailed actions enumerated in the Plan clearly aim to reduce those resources and minimize their importance.2
Despite the Plan’s narrow focus, it will affect depository libraries. Indeed, because of the inextricable connections between GPO and FDLP libraries, the Plan, as written, will affect FDLP in many lasting ways — most of them negative. The cumulative effect of these management and governance actions is not to enhance participation or partnership, but to increase GPO’s control over information while diminishing the value that individual libraries get from being an FDLP member and minimizing the ways that FDLP members can participate in providing “a user-centric approach to permanent public access.”
The result of this focus is a Plan of explicit GPO actions that will result in an FDLP of shrinking membership, shrinking collections, and diminished value, with FDLP members being indistinguishable from non-members.
Fortunately, small changes in the Plan can turn this around and create a practical strategic planning framework that will enhance and improve long-term preservation and access in ways that are measurable and clearly visible to users of government information. As an additional benefit, such a framework will strengthen both organizations (GPO and FDLP), making them more sustainable over the long-term. This strategic direction will also encourage and enable individual FDLP member libraries to participate in the preservation of collections and the provision of services to communities of users and this will result in demonstrable value to their own parent institutional communities. It will also give individual FDLP member libraries measurable indicators that will demonstrate the library’s value in comparison to other (non-FDLP) libraries.
We believe that all these benefits can be achieved if the existing Plan is modified in two small ways. First, the report should be built on a single, clear Mission Statement. Second, the report should more clearly differentiate between principles (which guide decision making) and goals and objectives (which define what will be done and how it will be accomplished).
With these two small changes, the Plan will provide a better roadmap for identifying specific actions that are needed to achieve successful long-term preservation of government information for the use of communities of users.
1. The Mission
Strategic planning requires a clear Mission that gives an organization direction. The GPO Plan, unfortunately, does not provide one, clear Mission Statement, but, instead, provides one Vision, two Missions, and also mentions (without elaboration) the Mission that NAPA recommends.
[Vision] “To provide Government information when and where it is needed.” [pp. ii and 3 and 7]
[Mission] To provide readily discoverable and free public access to Federal Government information, now and for future generations. [p7]
[Mission] Keeping America Informed [p 11]
[Mission] “In the digital age, GPO’s core mission of authenticating, preserving, and distributing federal information remains critically important to American democracy.” [p4. NAPA conclusion]
Although each of these has merits on its own, none adequately articulates the primacy of information preservation or recognizes the varied needs of the many different communities of people that can benefit from using government information. Having four different (though similar) vague expressions of GPO’s Mission also makes it difficult to understand, justify, or evaluate what the specific goals and objectives of the Plan will accomplish and if they will actually help GPO “[move] forward in the digital age” [p.ii].
There are many views of what a mission statement should do and how it relates to goals and objectives. Most agree, though that it should be concise, inspiring, jargon-free, emotional, and memorable. GPO’s Vision Statement — “Keeping America Informed” — fulfills all of these requirements.
But, if “Keeping America Informed” is the Vision, what is the Mission? Most agree that a Mission should be a little more specific than a Vision, and that it should give the organization direction in a way that the Vision statement does not. It can also be aspirational. It is not as specific as Goals or Objectives, but it should be specific enough to provide a baseline against which every goal and objective can be evaluated to determine if the organization is heading in the right direction. It should answer the question “Why?” for any action the organization takes.
Because we agree with GPO that planning should encompass long-term free public access to government information for future generations, we suggest that the FDLP/GPO Mission should be based on OAIS, the international reference standard for the long-term preservation of information of any type or format.3 OAIS says that the primary focus of archival institutions should be on the preservation of information as driven by the needs of specific Designated Communities.4
We suggest a new Mission Statement for Strategic Planning of the GPO and the FDLP that does not deviate from the existing Mission Statements, but makes them more specific and useful:
GPO and FDLP should meet the long-term needs of its Designated Communities by ensuring the long-term preservation of and free access to curated collections of government information.
This new Mission Statement does three useful, practical things. First, it is a Mission for GPO and FDLP — not for GPO alone.
Second, it keeps the aspiration of free public access as part of the Mission.5
Third, it clearly sets the focus for the Plan’s goals and objectives on preserving information to match the needs of people — not just “providing” unspecified information for unspecified reasons. It shifts the Mission focus from being “all about access” [p3] to being about preservation of information for use by people. We believe that GPO understands and agrees with this concept, but that it has not expressed it clearly in any of its Mission statements in the current Plan.
The Plan uses the five “Principles for Federal Government Information”6 as a basis for its “Desired Outcomes And Actions” [p8-11]. The Principles, like the Plan itself, focus on the federal government’s responsibilities and obligations and do not mention the FDLP or libraries.7
- The public has the right of access to Government information.
- Government has the obligation to disseminate and provide broad public access to its information.
- Government has an obligation to guarantee the authenticity and integrity of its information.
- Government has an obligation to preserve its information.
- Government information created or compiled by government employees or at government expense should remain in the public domain.
These Principles are not goals to be reached but statements of values. A good strategic planning process needs to articulate such values. Values help an organization choose among alternative goals and objectives. Goals and Objectives define what actions will be taken and how they will be accomplished; Principles (values) guide and inform the development of Goals and Objectives.
Unfortunately, GPO uses the Five Principles, not as values for guiding goal-making, but as goals in themselves. This misuse of the Principles leads to the awkward section of the Plan: “Desired Outcomes And Actions” [p8-11]. In that section, GPO lists each Principle as if it was a Goal to be achieved rather than a value that helps choose among goals and objectives. For each Principle, GPO lists one or more objectives, which it calls “Outcomes.” For each Outcome, GPO lists one or more tactics or “Actions.”
This may seem to be a subtle point, but it is a critical one. The way the Plan groups goals with individual Principles is, at best, awkward and, potentially, error-prone. For example, the one goal (or, as GPO says, “Desired Outcome”) under Principle 4 (preservation) is about making government information accessible (which relates more to Principle 1: access), but the objectives (“Actions”) of this goal are all about preservation. If that sounds confusing, it is because it is confusing! The confusion arises, at least partly, because digital preservation and digital access are intrinsically inter-connected; thus the Principles of preservation and access should inform all goals rather than be separate goals.
In short, if the Plan were modified to use the Principles as guides for choosing and designing every goal, the Plan would benefit by being clearer, more flexible, and more comprehensive.
Developing and Organizing Goals
Although we are suggesting only two small changes to the Plan (focusing the Mission and using Principles as values rather than as goals), those changes will affect the actual strategic planning process and, specifically, the long section of the Plan that describes “Desired Outcomes And Actions” [pages 8-11]. This is appropriate because the small changes put much more focus on users of government information and on how GPO and FDLP can collaborate to meet the needs of those users.
One change to the “Desired Outcomes And Actions” section of the plan is a simple one. Currently, it is organized around the Five Principles. We believe that using the six functions of the OAIS Functional Model — which look a lot like how the historic FDLP has managed government information for the last 200+ years! — provides a more practical approach.8
- Archival Storage
- Data Management
- Preservation Planning
This approach creates the opportunity to choose and design goals (or “Desired Outcomes”) that will fulfill the OAIS functions instead of the Five Principles. Although there is overlap between the OAIS functions and the Five Principles, the OAIS functions are more complete and are specifically designed for organizations that wish to plan for long-term preservation and use of information. OAIS is a well-tested, internationally accepted model for long-term preservation and access. This approach also allows every one of the Five Principles to inform and guide every goal and objective and avoids the confusion of developing goals that might conform to one Principle but might conflict with another.
Using OAIS as an organizing principle for strategic planning also benefits both organizations (GPO and FDLP) and individual FDLP libraries in several ways. First, using OAIS as an up-front guide for designing all stages of preservation and access and management is both wiser from a practical point of view and demonstrably easier than trying to conform to OAIS after-the-fact.9 (GPO is preparing for an audit and certification of FDsys as a trustworthy digital repository using the metrics specified in the ISO 16363:2013 Trusted Digital Repository (TDR) standard which are based on OAIS.10). Second, it allows GPO to expand its preservation, access, and service activities to include FDLP libraries as partners under the OAIS concept of Archive Interoperability.11 Third, using FDLP libraries as explicit partners in preservation, makes it easy to include Succession Planning into the strategic planning for GPO and every FDLP library.12
Revising the Plan to use the Five Principles as values that inform and guide the selection of goals presents the opportunity to expand the list of Principles.
The existing Principles are good, but they are limited because they mostly present only the perspective and obligations of the government. Only one of the Principles is specifically about people who use government information and it is only about “access” — which is a concept that is narrow and limited when viewed in the digital age when just being able to get (“access”) information is only the first step of consuming, interacting-with, using, and re-using information.
Virtually every requirement of OAIS is built around the concept of “Designated Communities.” The concept of preserving information for use by people is critical to every aspect of OAIS. The concept drives the choice of what information should be preserved, how it should be preserved, how it should be described and made discoverable, and how it should be delivered. A key aspect of government information that is often overlooked in planning is that different communities of information users look for information, acquire information, and use information differently. In short, there are many communities of users. Trying to preserve government information for all users as if they were one big community will, therefore, ultimately fall short of meeting the needs of the different communities.
This suggests that a collaboration of GPO and many FDLP libraries will enable the FDLP to better address more needs of more Communities than GPO can do on its own. A new Strategy that starts with what the FDLP can do collaboratively is de facto better than the Plan‘s approach of reluctant obligation. FDLP libraries are the obvious first choice for partnering with GPO for several reasons. The FDLP already exists; it is enabled by Congressional Legislation; it has a long history of successfully meeting these two goals; it is (presumably) backed by each participating library; each FDLP library is at least modestly staffed with one or more (presumably) trained librarians with a dedication to government information.
Together, these suggest two new Principles for the FDLP:
- Each FDLP library must serve the preservation and access needs of one or more explicitly Designated Communities. These communities need not be geographically or institutionally based.
- Each FDLP library must be assured that the needs of its own institutional communities are met.
What GPO does affects FDLP libraries individually and the FDLP as a whole. By creating Principles for the FDLP under the new more inclusive Mission Statement opens the door for GPO and FDLP to collaborate in the creation of a truly digital FDLP ecosystem. It opens the door to new ways of preserving information and building collections and providing services that GPO does not have when it operates on its own.
What “Communities” might individual libraries serve? Citizens and the General Public of course, but we should also recognize that there are many different “communities” within and beyond those broad categories. For example, residents who are not citizens are important users (or potential users) of information from governments. Even broad categories of more specialized communities can be divided now into smaller communities that look for, acquire, and use government information in different ways. For example, not all users of Census Bureau information use the information in the same way. A voter who needs a single statistic (such as the current population of an Congressional district) will use government information in a very different way from an historical demographer or Sociologist who requires large quantities of data (such as census datafiles) suitable for statistical analysis.13
The Plan itself does not need to (and should not) enumerate the very specific needs of individual Communities. But it should include general Principles that acknowledge that there are and will be different needs.
This suggests new Principles that focus on people.
- The delivery format of government information matters. Information formatted for reading by humans serves a different purpose from information formatted for use by computers. It is often necessary to deliver the same information content in more than one format so that the needs of different Communities can be appropriately met. People have a right to information in a format that best suits their needs.
- People need to be able to find government information, its provenance, authenticity, and context. People have a right to adequate metadata about the information they require in order to evaluate and use and understand that information and to determine how it relates to other information.
- People need to have access to curated collections of government information that are selected, organized, and preserved in ways that meet the needs of their Community.
- Because of the special nature of government information, Communities are best served by librarians with specialized training and experience who provide information services in person and online and through Community-specific services
- Because different Communities need different content and make use of content in different ways, the needs of those Communities can be best met by developing different collections and services that focus on the needs of different Communities.
- Government information is for democratic (re)use
- Every document many citizens
- Every citizen many documents
- Save the time and dreams of the document reader
- The government information library is a growing commons
- Every document many access points
Using OAIS as a basis for strategic planning for GPO and the FDLP, will, by design, result in many benefits for users of government information. Simply by providing better collections and services for users, FDLP libraries will increase their value to users in ways that users will get and appreciate every day. Here are some examples of benefits that a collaborative digital FDLP will provide to each FDLP library:
- the ability to create a customized collection tailored to each of its designated communities;
- the ability to customize the presentation of each collection to the way each community uses the information;
- the ability to combine non-federal-government content, “fugitive” content, and non-FDLP content with FDLP content into a coherent, integrated collection;
- the ability to customize the delivery and utility of content to match the way each community uses the content;
- the ability to seamlessly, transparently point to multiple copies of the same item so that if one site or server is ever down or unreachable, a user request can be automatically transferred to an available site/server with the same content;
- the ability to customize services for collections;
- the ability to seamlessly, transparently refer users to collaborative service-provider partners;
- the ability to have control over content to prevent deletion or tampering even if other collaborators no longer want that content.
We believe all these benefits will start with a Mission that is focused on preserving information for use by people and will be driven by values held in common by GPO and FDLP libraries.
New Goals and Objectives
In order to achieve those benefits, the “Desired Outcomes And Actions” section of the Plan will have to be evaluated. Before doing that, we will examine, in Part II of this series, the current environment within which strategic planning must take place: The Strengths, Weaknesses, Opportunities, and Threats associated with preserving government information for long-term access and use.
- GPO initially charged fees for GPO Access, its first online service (See: Status report: GPO Access. June 30, 1994). When that failed because FDLP libraries made the same content freely available on the web, GPO was forced to drop fees. Eight years later, then Public Printer Bruce James wanted to go back to charging fees, saying that providing content for “free to the general public…cannot continue” (See: Admin Notes, v25 n3, February 25, 2004 page 12); this was even written into that year’s Strategic Plan (Dec 2004), which said that “by law and tradition” one of GPO’s “three essential missions” was “To distribute, on a cost recovery basis, copies of printed and electronic documents and other government information products to the general public.”
- See, for example, the suggestions that will reduce collections [p9]: implementing the regional depository discard policy, allowing for shared regionals across state boundaries, and having “online” as a format selection option for regionals to replace paper and microfiche. The Plan also suggests increasing the number of “depository” libraries without collections by increasing the number of “all digital depositories” (a euphemism for libraries into which nothing is deposited) and creating a new “affiliate” depository designation — both which result in libraries without collections. All this indicates expansion of existing policies that minimize or even eliminate the “resources” (collections) that “depository” libraries have under their own control. Much of this was made possible by the revisions in 2014 of the Legal Requirements and Program Regulations of the Federal Depository Library Program. Another action in the Plan suggests further unspecified revisions to those Requirements. See also: All or Mostly Online Federal Depository Libraries.
- Consultative Committee for Space Data Systems. (2012). Reference Model for an Open Archival Information System (OAIS) (Magenta Book, issue 2). Washington, D.C.: Consultative Committee for Space Data Systems.
- “Designated Communities” is an essential concept of OAIS. It is defined as “An identified group of potential consumers who should be able to understand a particular set of information. The Designated Community may be composed of multiple user communities. A Designated Community is defined by the Archive and this definition may change over time.”
- It is particularly important to express free access as part of the Mission because the GPO Vision and at least one of the existing Mission statements and the NAPA recommendation do not. In contrast, fees are allowed by Title 44 (44 USC §4102) and even by Principle 1. In addition, one of GPO’s “Assumptions” (“Collaboration and partnerships with … private sector entities are necessary…” [p7]) presumes fees for access. There is also a precedent for charging fees to the public for access (see Endnote 1, above). Although GPO has (mostly) not charged fees for 20 years, there have been repeated calls over the years for GPO to do so including, most recently, by the NAPA report itself (which The Plan cites as one of its “Drivers Of Change”); see: NAPA releases report on GPO and Privatization of GPO, Defunding of FDsys, and the Future of the FDLP.
- The Principles as included in the Plan [p6-7] are lightly edited versions of those that were originally included in a 1996 GPO report to Congress: Study to Identify Measures Necessary for a Successful Transition to a More Electronic Federal Depository Library Program As Required by Legislative Branch Appropriations Act, 1996 Public Law 104‐53.
- Three of the Principles are about obligations of government, one Principle is about the rights of the Public, and one Principle is about Government Information remaining in the public domain.
- The Functional Model is explained in detail in section 4.1 of OAIS. The six functions apply to all kinds of content, not just digital content.
- This statement is based on over five years of James A. Jacobs’ experience with the Center for Research Libraries in auditing repositories for certification under TRAC and OAIS.
- ISO 16363 (CCSDS 652-R-1) Audit And Certification Of Trustworthy Digital Repositories.
- OAIS section 6.
- Succession Planning is a key requirement of OAIS (section 3.2.5), TRAC (section 1.2) and TRAC’s successor TDR (section 22.214.171.124)
- For other case studies of modes of access, see “Beyond LMGTFY: Access to Government Information in a Networked World”, by James A. Jacobs and James R. Jacobs. in Public Knowledge: Access and Benefits, Edited by Miriam A. Drake and Donald T. Hawkins. Medford, NJ: Information Today, Inc. (2016). pages 21-32.
- Books are for (Re)Use, by Barbara Fister, “Library Babel Fish” Inside Higher Ed (March 20, 2014).
James A. Jacobs is Librarian Emeritus, University of California San Diego.
James R. Jacobs is the Federal Government Information Librarian at Stanford University’s Cecil B. Green Library and program lead for the LOCKSS-USDOCS program.