Analysis of COL FDLP task force final report #alaac14

June 26, 2014 by
Filed under: Commentary, Library, post 

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James A. Jacobs and James R. Jacobs, Free Government Information (FGI)

On Monday, the ALA Committtee on Legislation’s (COL) FDLP task force released its final Final Report and Recommendations.

  • American Library Association. Committee on Legislation, Federal Depository Library Program Task Force. Final Report and Recommendations. Maggie Farrell, Chair. (June 23, 2014). http://connect.ala.org/node/225583

This is the result of a series of discussions, reports, a survey, and solicitations of comments over the last two years designed to examine the Federal Depository Library Program (FDLP) and options for its future. The purpose of all this work was to examine diverse opinions and guide the policies of the American Library Association (ALA) regarding the FDLP.

Below, we provide some background, analysis of the final report, and some recommendations.

Background

In 2012, the ALA’s Committee on Legislation formed its FDLP Task Force to “examine a set of questions and issues to guide the Committee on current aspects of the FDLP and options for the future.” The Task Force then held a number of discussions online and via conference calls from July 2012 through June 2013 with a goal of focusing on actions and directions that ALA might take to “advance the program.” The Task Force released a “Draft discussion document” that covered six issues, and twenty-two discussion questions; it included summaries of the discussions of these and offered twenty recommendations. Four days later, the Task Force released a report with twenty-one recommendations.

Although the discussions and recommendations did result in some degree of consensus on many individual points, there was still some controversy over the Task Force’s focus and vision as a whole and an apparent need for the Task Force to make more specific recommendations as to how COL (and ALA) should proceed. So, at ALA Annual 2013, the Task Force was asked to continue for an additional year to “outline a process for ALA to bring together diverse opinions and to guide COL in its future consideration of policies regarding the FDLP.”

In December 2013, the Task Force created an online survey (https://www.surveymonkey.com/s/FDLPTaskForce) that focused on a single, broad issue, “a national preservation plan for depository materials,” in order “to understand how ALA might develop consensus and advance broad association goals” and address a variety of issues including “geographical distribution, metadata, partnerships, training, and advocacy.” The Task force distributed the survey online to ALA members, invited ALA Divisions and Roundtables to formally respond to the survey, and conducted an open dialogue forum during ALA Midwinter 2014 in Philadelphia. In response to the survey, GODORT’s Committee on Legislation wrote 7 statements as the Round Table’s official submissions to the ALA Committee on Legislation’s FDLP Task Force survey (full disclosure, James R. Jacobs is currently a member of GODORT LegComm and participated in putting the GODORT statements together). The statements were voted on and agreed to by GODORT Steering at Midwinter 2014 conference. Statements included ones on born-digital government documents, digitization and preservation of historic / paper government documents, the FDLP as a historic and sustainable structure going forward and the role of federal libraries within the FDLP.

On June 23, 2014, the COL FDLP Task Force released its final report.

  • American Library Association. Committee on Legislation, Federal Depository Library Program Task Force. Final Report and Recommendations.  Maggie Farrell, Chair. (June 23, 2014). http://connect.ala.org/node/225583

The Final Report offers the same twenty-one recommendations from 2013 without any changes. It summarizes the Task Force’s year of work with  "recommendations" (page 2 of the Final Report) that suggest that ALA should facilitate the development of a national preservation plan and partnerships and strategies that advance the FDLP, and that ALA and GODORT should develop core competencies for the "use of FDLP resources." It also says that FDLP resources and services are important to many ALA units and suggests that ALA and its units should work together collaboratively on FDLP issues.

Analysis

The FDLP Task Force’s Final Report and Recommendations has retained both the good and the bad ideas from its earlier report, but its real flaw is a lack of focus on users of government information and a lack of a vision of how to ensure long-term, free access to government information.

Good Ideas

Some of the good ideas in the report include: (numbers refer to recommendation numbers)

  • Recognition of the need for a comprehensive national preservation plan for government information (#1, #8).
  • Using the FDLP registry to coordinate digitization efforts and avoid duplication (#2).
  • Suggesting that GPO should coordinate and facilitate digitization projects (#4).
  • Recognizing the need for authentication of [digitial] government publications (#5).
  • Recognizing the need for "geographic distribution" of digital storage, preservation, and access (#10). 
  • Suggesting that ALA accreditation of library schools should include "appropriate training/information on government information" (#11).
  • Recognizing that providing free access to government information is essential (#3, #7).
  • Recognition of the value of digitizing paper collections (#1, #2, #4, #6).

Bad Ideas

Some of the bad ideas in the report include:

  • Using the destruction of print collections as the only reason for developing a preservation plan (#1, #8).
  • Presenting a confusing, convoluted, unclear idea that commercial sources can be relied on as trusted sources of government information and can be included in the FDLP guidelines for discarding government information as long as neither libraries nor users pay for these commercial products (#7).
  • Diminishing the value and changing the role of FDLP libraries by passively accepting that, in the digital age, FDLP libraries may not (and, presumably, should not) be relied on to store or preserve digital content and a concomitant recommendation for new guidelines to define (presumably non-FDLP) “partners” to provide digital storage and preservation and access (#10).
  • A call for “flexibility” and a recommendation to advocate changes to Title 44 of the US Code (#21) (the part of the US Code which codifies “Public Printing and Documents” and defines the FDLP) without any definition of what this “flexibility” is or how it might be identified or how changes to Title 44 could either ensure that unspecified flexibility or avoid damaging the FDLP or user access to government information. (The main use we have seen of the term “flexibility” in the FDLP community has been as a code word used by libraries that want to renege on their Title 44 commitment to preserve paper collections by having the "flexibility" to discard them.)

Omissions

In addition to these bad ideas, the report also is notable for what it omits and how it glosses over many essential issues with vague language. Even some of the "good" recommendations listed above suffer from vague wording which obfuscates the value of the proposal. 

It is hard to understand how these recommendations can guide COL or ALA on current aspects of the FDLP and options for the future when it leaves out all mention of:

  • Born-digital Content. (James A. Jacobs’ recent report for the Center for Research Libraries, "Born-Digital U.S. Federal Government Information: Preservation and Access", demonstrates that there are more born-digital government information items produced in a single year than all the non-digital government information items accumulated in the FDLP over 200 years. The Task Force report fails to mention born-digital content at all. It limits its recommendations that deal with digital content to digitizations [#1, #2, #3, #4, #6] and one single, vague mention of digital storage [#10].)
  • The weaknesses of the current model of preservation and access. (Since roughly 1993, most FDLP libraries have relied on GPO and government agencies to provide access, service, and preservation for digital government information. The recent loss of access to government information during the government shutdown and the two-weeks-long GPO PURL server crash of 2009 should convince everyone that the government cannot guarantee long-term preservation of government information on its own. The Report’s commitment to "free access" rings hollow in this context when we realize that agencies — including GPO — are explicitly allowed to charge for access. The Report fails to address how libraries can preserve or ensure access to anything when they leave the selection of what will be preserved up to individual agencies and relinquish their own ability to do so.)
  • The need for new skills. (The Report does not just omit this, it explicitly rejects it. Recommendation #17 actually abjures the need for "additional requirements"  for FDLP libraries at a time when ALA and COL could be taking a stand on the need for new, digital skills. Examples of such skills include: building Trusted Digital Repositories, providing robust online services for complex full-text collections, developing digital infrastructures and data repositories that are flexible enough to cope with a rapidly evolving technological environment for increasingly sophisticated users, and developing new techniques for acquiring and preserving dynamic content in multimedia formats — to name just a few.)
  • Services. (While recognizing that some unspecified “FDLP services” — presumably reference — are important, the report provides no recommendations on how to provide those services in an era when, according to the Task Force, Library administrators are finding it “necessary to cut staff and merge services.” The implication of the Report is that "services" will be replaced by "access" to digital content and by reduced access to print materials.)
  • Collections. (The only recommendations that address collections speak of the "destruction of [print] collections" [#1] and how the digital collections of commercial vendors "cannot replace free public access to FDLP materials" [#3]. Although the report does emphasize the need for a comprehensive preservation plan, it only does so within the context of destruction of documents and the reduction of geographic distribution of printed FDLP documents [#1, #8]. One of the strengths of the FDLP has always been its diverse collections that meet the needs of different user communities. The digital environment demands an even greater need for focused collections to enable and facilitate better discovery and customized usability of digital objects; at the same time, it provides the opportunity for libraries to expand their user communities beyond the geographically-local. Similarly, shared digital collections will require much more work on discovery, access, delivery, preservation, online services, and usability than has so far been done. The report is silent on these matters.)
  • Users. (Most importantly, the Report pretty much ignores the needs of users. The only mentions it makes of the needs of users are the importance of free information, and their need for "instruction." The Report focuses on ALA and COL and, to a lesser extent, on a vague, abstract vision of the FDLP. How can the Task Force make recommendations without knowing what the needs of users are? How can it justify any recommendations without describing how they will affect users of government information? Because of the lack of a user-centered approach, the recommendations seem to be a list of various unconnected, predetermined tactics that are not linked to outcomes or user needs. The Report fails to even mention how they expect these tactics to affect users.)

Though the committee includes former and current government information librarians who we know and respect — including Maggie Farrell who just lost a tight race for ALA President — we were left with a feeling that the report lacked focus and an overall view of the future of the FDLP.  It was perhaps inevitable that a committee report of this kind that gathered diverse opinions from many sources would end up reading like an unordered list of ideas and recommendations without context. That is probably more the fault of the charge of Task Force than a fault of the Task Force itself. But it limits the usefulness of even the best intentioned of its recommendations.

In its current state, the Report reminds us of a grocery list without a menu. Sure, it’s always a good idea to pick up eggs and milk and butter (the good ideas) — but are we getting the right ingredients in the correct proportion? Are we baking a cake or making an omelet? And do we really need that two-gallon can of anchovies (the bad ideas)? Many of the individual ingredients are good, but how will we assemble them into something tasty and nutritious? How will COL and ALA translate these into actions that will have the desired results for users if we don’t specify the results we want to achieve? How will we determine whether or not we have succeeded? One thing we do know is that our users will know — particularly if we serve them an anchovy cake.

As noted above, the report seems like an almost random collection of tactics that libraries had already chosen before the Task Force started its work: the destruction of historic collections, reduction of FDLP geographic distribution, vague paeans to education in the “value of federal information,” competencies in “instructing library users in the reliability and authoritativeness of government information,” and the need for knowledge of unspecified "government information tools." But the Report fails to connect any of these tactics to goals or outcomes.

We at FGI followed the Task Force closely and wrote some detailed criticisms of the early versions of the recommendations and of discussion items and the way the Task Force framed the discussion. (See the “Postscript” below for references to those writings.)

Apart from those criticisms, we must add now a final over-arching criticism that we see as a fatal flaw: We think that the report lacks context, vision, and direction. The Report fails to describe how, even if every recommendation were carried out fully and successfully, users would have access to the services and collections they need.

Recommendations

We believe that COL should ask the Task Force to provide additional context for its recommendations. Specifically, it could start with its own “recommendation” (actually more of an assertion — currently listed as recommendation #20) that “The FDLP core values remain fundamental in a digital environment and continue to be relevant.” If the Task Force truly believes this and has found agreement to this assertion among its diverse respondents, it provides a good starting point because it begins with the existing strengths of the FDLP and offers an opportunity to build on those strengths. Those strengths of the FDLP are:

  • It provides the government and the library community with a legal foundation and tradition of free, long-term preservation and access.
  • It provides over 1,200 libraries and their staffs that have committed to free, long-term preservation and access.
  • It provides the FDsys infrastructure that is actually doing a very good job of preserving and providing access to Congressional information, and has made some headway into doing the same for Judicial and Executive branch information.
  • It builds on existing, innovative FDLP technological partnerships such as GPO’s alliance with LOCKSS-USDOCS, which is an excellent preservation model that demonstrates the value of digital-deposit and distributed responsibility for digital preservation. (This shows that if GPO wants to do digital deposit, it can — without changing Title 44. It also demonstrates that libraries can participate and do so without a large investment in staff or funds. If FDLP libraries want to move into the digital age and not hope that someone else will fulfill their role of providing collections and services, this shows they can.)

The Task Force could then use its existing research (and supplement it with more, if necessary) to describe and define current user needs, and to define a National Government Information Infrastructure that will meet the future needs of users. Doing this would almost certainly lead to the Task Force recommending a "comprehensive preservation, access, and service plan" to replace existing recommendations that only address preservation. (As many have pointed out, in the digital age, “preservation” and “access” are immutably linked. And, as every librarian and every commercial information provider knows, collections without services have no value to users.)

The Task Force could then re-order, and re-combine its existing recommendations into this new framework, adding text that would link recommendations to outcomes and effects on users. Finally, it could add new recommendations or adapt existing ones in order to address those important issues it left out (see "Omissions" above).

The revised report would have several demonstrable strengths that the current report lacks. It would recognize that paper is currently being preserved and digital is not and that there are existing proposals to discard paper without explicit plans for meeting even existing low-levels of service or long-term public access. Most importantly, the revised report must begin with the important ingredients needed to assure the future of the FDLP and access to government information:

  1. User focus; permanent free access to govt information. (One big way to inject users into the system is to adapt current bibliographic tools to allow for user input to help set priorities in digitization and preservation and expand description to aid in future access.)
  2. Geographically distributed preservation of government information in all formats, including a large-scale, managed cataloging effort, a need for flexibility of digital copies to adapt to future uses and devices, and an admission that historic paper collections will continue to be needed by users around the country regardless of digitizations.
  3. Training and education program for incoming and current government information librarians that includes the skills necessary for a 21st century hybrid library. 
  4. Preservation, Access and Service Plan that includes an inventory of what libraries currently have (number of copies, format, quality, utility, preservation-status, discoverability, re-usability, metadata), physical access standards, and a vocabulary for describing user-centered life-cycle creation, storage, preservation, discovery, use, and reuse.

Once we know what we’re cooking (a better, more sustainable system for libraries to help support public government information access and (re)use over the long-term), and once we have a list of the right ingredients we need for that (the Task Force’s new recommendations), libraries and librarians in concert will be able to follow through knowing what we expect to accomplish and knowing that we are taking steps to get there.

Postscript

Here are links to earlier writings on the Task Force’s work in which we at FGI provide more details than we have given here and additional arguments for a different approach.

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