Analysis of the Regional Discard Policy: What you need to know about implementation
Now that GPO is
testing the implementation of implementing the Regional Discard Policy, it is time to finally get answers to the important questions that GPO has not addressed over the last two years.
Although we have asked many questions about this policy, our concerns boil down to one simple question: Will FDLP — and more importantly, the public! — lose information when Regionals discard their historic collections? To answer that question, we just need to know if GPO’s implementation of the Policy will ensure that the paper preservation copies of discarded volumes and their digital surrogates are complete and accurate.
We now know that the implementation will not prevent loss of information.
In October 2015, GPO announced that it would begin testing processes and procedures of the new Regional Discard Policy with six regional depositories in January of 2016. GPO provided little description of how the policy would be implemented beyond the policy itself, leaving many important questions unanswered.
GPO has now provided links to three draft implementation documents, a recording of an information webinar, and some other “informational resources.” This provides the FDLP community with the first indications of how GPO is interpreting its new Policy and how it intends to implement it.
There are still many unanswered questions, but we now have the first solid indications of how GPO intends to balance preservation of (and access to) the FDLP Historical Collections while discarding them.
We analyzed GPO’s earlier implementation statements in a previous post. We also asked specific questions about implementation in an open letter to GPO, and, in a separate post, we review the few answers to those questions that we can infer from this new batch of documents.
In this post we focus on the big picture and the most important things FDLP librarians need to understand about GPO’s implementation of the Policy.
GPO interprets "Access" to mean "Preservation"
When the Joint Committee on Printing (JCP) — the committee charged with oversight of GPO — approved GPO’s Discard Policy, it imposed one condition that GPO had not asked for: that FDLP retain at least four tangible copies, distributed geographically, for the purpose of meeting GPO’s needs but also for "providing the necessary access to the materials."
We now know how GPO is interpreting this. According to the Memorandum of Agreement (MOA), these copies will not be used for “providing necessary access” as JCP directed; they will instead be considered "Preservation Copies of Record." GPO defines these as a "version set aside to protect its informational content and intrinsic value from decay or destruction" stored in a "Controlled Access Environment … in which library users cannot directly browse and pull material from library shelves."
Paper preservation copies may be defective
The MOA defines the "Preservation copy of record (for tangible publications)" as being "The average used and worn publication that has all pages or leaves present." But GPO does not describe how (or who) will determine if all pages or leaves are present. The MOA also says that "any defects must be noted" — which presumably means that incomplete and damaged copies can be considered "preservation copies of record." Indeed, the procedures seem to anticipate that stewards will have damaged paper copies: A regional library that wishes to discard a title is instructed to send a copy of that title to the Preservation Steward if the discarding library’s copy is "in better condition than that of the Preservation Steward." But, again, the current implementation documents provide no procedures or instructions or standards that a library could use to compare copies or determine which copy is "better."
Impermanent Preservation of paper copies
We also know that those "Preservation copies of record" will be "preserved" by reliance on temporary contracts. GPO’s replacement of the legislative mandate for regional libraries to preserve the Historic Collections permanently is a “Memorandum of Agreement” that can be cancelled at any time. These MOAs between GPO and "Preservation Stewards" will specify that each steward will store one copy of a specific list of titles that are eligible for discard. The MOA "expresses" a "commitment" to permanent preservation, but does not obligate the stewards to a permanent (or even long-term) commitment. In fact, the agreement explicitly allows the steward library or GPO to terminate the agreement at any time by giving 120 days written notice. According to the FAQ, the agreements will even be reviewed every three years "for continuation." If a steward library ever wants to cancel the contract for preservation, it can do so without asking permission of anyone.
GPO makes preservation promises it cannot keep
The MOA says that, if a steward library cancels its agreement to store paper copies covered by the agreement, GPO "will find another depository library" to store those documents or will store those documents itself. In saying this, GPO contradicts itself and makes a promise that, by its own reasoning, it will likely not be able to keep. On the one hand, GPO has insisted that libraries need to discard paper copies and on the other hand it is promising that it will be able to find an unknown number of libraries (depending on how many libraries cancel their MOAs) to house an unknown number of documents — after those very documents have (presumably) been discarded. What makes GPO think this will be easy to do or even possible? GPO’s promise to store the documents itself contradicts another part of the MOA which says that GPO does not have a tangible collection and therefore it has to rely on preservation stewards for preservation storage.
Less Access: No Inter-Library Loan of paper copies
We have found no mention of Inter-Library Loan in the documents provided by GPO, but the MOA does limit use of the "Preservation Copies" to "in-building use only or for use in a special collections reading room." Presumably, this will prohibit those copies from being loaned through ILL. (The MOA also says that "The copy of record may be nondestructively digitized to create a digital surrogate to function as the use copy" but it is not clear why this is necessary since there is already supposed to be a digital copy in FDSys for that purpose.)
No guarantee that digital copies will be complete or accurate
GPO and others have argued repeatedly that the Discard Policy is reasonable because people will use the digital copies in FDsys. This argument becomes meaningless if the copies in FDsys are incomplete or inaccurate.
Unfortunately, although the Policy asserts that those FDsys copies will be complete, it provides no procedures for determining either completeness or accuracy — though we already know beyond a doubt that such digital surrogates contain errors and missing pages (Conway). The MOA has a single requirement for the "digital copy of record": it must be "produced to specifications that will allow the creation of a printed facsimile version." Separately, the "Instructions for Regional Depository Libraries to Request Approval to Discard" specify that the digital copy in FDsys must be "complete (no missing pages)," but, again, GPO provides no procedures to ensure such completeness. (The Instructions do specify that, for a title to be added to the list of titles eligible for discard, a library must compare the digital copy to the tangible copy to ensure they "match." But GPO’s instructions for this comparison only focus on determining if the two are “the same document,” not if the digital copy is complete.) Neither is there any requirement to determine if the digital copy is accurate. This is a significant omission because most of the volumes that are the targets of the Discard Policy ("more than one million titles" according to Vance-Cooks) will be digitized copies of print-originals. The best study we have so far (Conway) estimates that 35% of such titles are not accurate and complete enough to be considered “reliably intelligible surrogates.” (See also The Digital-Surrogate Seal of Approval: a Consumer-oriented Standard.)
The above are facts. If you read all the documents, you also get an impression of how GPO is implementing the Discard Policy so far.
One impression we get is that GPO is bending over backwards to make it easy for Regionals to discard documents and for libraries to sign on as Preservation Stewards. If the requirements for discarding and for providing stewardship included procedures that would ensure against loss of information content, it might be harder to discard and more difficult to attract “stewards.” This means that, although GPO is keen to express its goal of preservation and access, it is not translating that goal into actions that will ensure either.
Second, the risk of loss of information with these implementation procedures is high. Consider the fact that most of those one million titles that Regionals are eager to discard are born-analog print-originals. The only way those volumes will become eligible for discard is for someone to digitize them and for GPO to ingest them into FDsys. What standard has GPO set for such digitizations? The lowest possible standard: page-images. What procedures and standards is GPO requiring to ensure those digitizations are complete and accurate? None. As noted above, the most reliable study available tells us that more than one third of such digitizations are not complete and accurate. GPO’s announced procedures are a recipe for discarding complete and accurate publications and replacing them with inaccurate and incomplete digital copies. Libraries that moan that they do not understand why users do not value them should ask themselves how their users will react when they learn that we could have prevented this loss, but instead chose to create it.
Third, we are dismayed that the procedures are legally temporary. Nothing prevents libraries from cancelling their MOAs and GPO’s procedures for dealing with that are not only weak, they are demonstrably unrealistic.
Finally, we have to look to the future. The current GPO administration admirably declares that long-term preservation and access are essential parts of its mission. But, if even this GPO administration cannot or will not take the actions necessary to uphold those values, what will happen when a new administration with less admirable values takes over? When this administration can essentially ignore JCP instructions to provide paper copies for access and when it can use temporary contracts to provide permanent access, what will a less enlightened GPO do in the future? Given that GPO is bending over backwards to accomodate the demands for “flexibility” from a few libraries, and rushing to do so without adequate research, testing, or data, and without safeguards in place to prevent loss of information, what will keep a future GPO administration from abandoning any of these lip-service “commitments” by simply cancelling the MOAs?
Since the implementation is (presumably) still being tested and since the implementation documents provided are drafts, what we know so far is still preliminary. There is still time for the FDLP community to stand up and demand better. The next opportunity to do so is the fall 2016 Depository Library Council meeting and conference. FGI will be there. Will you?
- Policy: Government Publications Authorized for Discard by Regional Depository Libraries. Superintendent Of Documents Public Policy Statement 2016-3. ("SOD-PP-2016-3") Effective: 05/31/2016.
- Draft MOA: DRAFT Memorandum of Agreement (preservation stewardship) (Rev: 07/07/2016). [Also referred to as "Memorandum of Agreement (MOA) for Preservation Stewards (DRAFT)"].
- FAQ: Implementing Phase One of the Regional Discard Policy Frequently Asked Questions (FAQ) ("Draft"). (July 11, 2016). [Also referred to as "Regional Discard Implementation Frequently Asked Questions (DRAFT)" and "Implementing Regional Discard Policy FAQ"].
- Letters: from Vance-Cooks to JCP and JCP’s response: Both documents in one PDF file here. 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]
- Instructions: Instructions for Regional Depository Libraries to Request Approval to Discard ("Draft") (July 11, 2016). [Also referred to as "Instructions for Submitting Discard Requests to GPO (DRAFT)" and "Discard Request Instructions"].
- Conway, Paul. (2013). Preserving Imperfection: Assessing the Incidence of Digital Imaging Error in HathiTrust. Preservation, Digital Technology & Culture. v42 no1, (17–30) DOI: 10.1515/pdtc-2013-0003.
Authors: James A. Jacobs and James R. Jacobs