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Library associations weigh in on GPO’s proposed policy to allow Regionals to discard

Mueller-proactive-conventional-wisdom[Update 12 September, 2014: I’ve added below links to the letters of the FDLP Regional Librarians group and of the Depository Library Council (DLC). I struck out my comment about GODORT being the only group comprised of govt information librarians. JRJ]

I thought it’d be helpful to post the various letters in response to Government Printing Office (GPO) Superintendent of Documents’ recent proposal to allow Regional Depositories in the Federal Depository Library Program (FDLP) to do “e-substitution” and discard some government documents that are authenticated on GPO’s Federal Digital System (FDsys). We have commented before on this proposal (see “Why GPO’s proposed policy to allow Regionals to discard is a bad idea”). the title, as well as the choice of comic, will tell you what we think of the proposal ;-)).

But I think it’s interesting to compare the letters from the American Library Association (ALA), American Association of Law Libraries (AALL), Association of Southeast Research Libraries (ASERL), Association of Research Libraries (ARL), and ALA’s Government Documents Round Table (GODORT). All of the associations but GODORT are in favor of the proposed rule change — though AALL brings up similar issues of concern to GODORT — but GODORT is the only group comprised wholly of practicing government information librarians working daily with this corpus. It should also be noted that GODORT’s recommendation is not strictly opposed to the proposal, but their letter says that research should be done *first* to put the community on solid ground before going forward with irreversible discards. All of the letters agree that FDsys should undergo a TRAC audit, and all agree that there remains a need for a geographically distributed “requisite number of tangible copies” of government documents — ASERL says a few as 5 – 10 copies will be sufficient, while AALL hints at a larger, as-yet-unknown number. ASERL and ARL state that the policy should be expanded to include e.g. HathiTrust content and “documents scanned by FDLP libraries and other reliable content providers.”

ALA letter to GPO:

“The proposed policy takes steps to allow flexibility while seeking to retain the accessibility and preservation of the collections. We support this policy change as regional depository libraries must balance space constraints, staffing pressures, and increased electronic documents. Given that usage for in person retrieval of depository items has decreased, the pressure to make changes to these collections has increased. That said, ALA does not want to hinder long term preservation of government information in order to make this possible.”

They support the policy change, but raise concerns including:

–What is the “requisite number of tangible copies” and what would be their geographic distribution? As an official study has not been done, when and how would GPO make this consideration?

–How long would regional libraries need to wait after making a request to discard and what would this process entail?

They recommend a TRAC audit of FDsys be done as it will be “beneficial for its long term success to be independently audited and certified.”

AALL letter to GPO:

AALL is generally in favor, but:

“strongly believe[s] GPO must ensure that tangible items continue to be geographically dispersed so as to meet the needs of the public and the requirements under Title 44” … and “requests further discussion about the definition of “requisite number of tangible copies.” Interestingly, they note “It is possible that law libraries may conclude that more copies of print legal materials are needed to ensure public access to the law, both current and past. It is possible that law libraries may conclude that more copies of print legal materials are needed to ensure public access to the law, both current and past.”

They also want clarification on some points, including how the Superintendent of Documents will prioritize requests to discard, and wanting a list of eligible FDsys collections which are currently authenticated and complete. They make the point that “it is possible that many regionals will request the opportunity to discard.”


“encourage[s] GPO to pursue Trustworthy Repositories Audit & Certification (TRAC) to verify FDsys’ status as a Trusted Digital Repository” and “applaud GPO for its ongoing partnership with LOCKSS-USDOCS, which helps to ensure access through its geographically distributed sites and multiple replications. We urge GPO to continue to pursue partnerships with libraries, nonprofits such as the Internet Archive and DPLA, and other institutions that can support GPO’s responsibility to provide permanent public access. Some depository libraries may also have capabilities to conduct digital deposit, and we encourage GPO to explore this option.”

ASERL’s letter to GPO:

“ASERL has long been concerned that the current FDLP model requires more print collections than appears to be necessary to satisfy the need for the American public’s access to FDLP content. As a result, many FDLP libraries struggle with supporting significant, unnecessarily-redundant legacy print FDLP collections, many of which go largely unused. We are encouraged to see GPO consider new ways to balance the print-electronic transition; exploring ways for Regional depositories to consider weeding portions of their legacy print content when good-quality electronic substitutes are available is a fine place to start.”

ASERL makes 7 points, including recommending “TRAC certification in the future to become a Trusted Digital Repository, to ensure electronic access to FDLP content remains reliable for the foreseeable future. This is a long-term objective; we feel TRAC certification should not delay implementation of this discard policy/process.” They also want GPO to “provide incentives for depositories to take on print retention commitments, such as providing cataloging records for legacy collections via OCLC to ease collection management responsibilities, and procuring large scale digitization of the legacy print corpus as well” … “develop means to authenticate additional content — including documents scanned by FDLP libraries and other reliable content providers” … and “identify and provide support for a non-governmental electronic repository (e.g., Hathitrust) to serve as an official supplementary access point to the growing collection of electronic FDLP content.”

ARL’s letter to GPO:

“Current law, section 1912 of Title 44, authorizes regional depository libraries to manage the disposal process of government publications. Given the years of experience and best practices that have been adopted by these libraries, regional depository libraries should continue in this role in lieu of new roles for GPO. Imposing potentially new regulatory burdens on these libraries would negate the new flexibilities the proposal seeks to introduce.”

“GPO should also proceed with the TRAC review (e.g. certification and assessment) of FDsys that had been previously agreed to but not undertaken. As GPO has already decided to move forward on such a certification, this would not in any way lead to a delay in implementing the proposal…”

“…ARL very much appreciates that GPO understands electronic access is a preferred manner of access to government information for the public. To that end, we believe that the proposal as currently drafted should provide greater clarification and be expanded to a greater number of government-produced publications.”

GODORT’s letter to GPO: (note: I’m linking to FGI because the GODORT letter is posted to ALA Connect which requires a user name/password for access)

“Because the community has yet to conduct research on or come to consensus about the number of copies and geographic distribution of historic physical documents necessary to assure preservation of and access to the FDLP collection, GODORT finds that it is in the best interest of the long-term viability of the FDLP to first conduct research on the national collection before beginning to allow regional depository libraries to do any electronic substitution…”

“…In general, GPO policy changes that will result in withdrawal and discard of materials from regional collections should be based on evidence that shows that the changes, at minimum, will do no harm and preferably will provide a demonstrable benefit to public access and preservation. Prior to the establishment of any policy allowing electronic substitution for regional depository libraries, we highly recommend that substantial progress be made in assuring permanent access to tangible materials, born-digital files, and digitized surrogates of historic tangible materials…”

“…The need for FDsys, including its succession plan, to be independently audited by a trusted organization for long-term reliability under internationally-recognized standards such as TRAC becomes more pressing as reliance on its contents increases.”

Letter from the FDLP Regional Librarians. See my comments and questions below.

Letter from the Depository Library Council to the Public Printer

CC BY-NC-SA 4.0 This work is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.


  1. You did not include the Regional Depository Librarian’s letter to the Superintendent of Documents. See below.

    August 26, 2014
    Mary Alice Baish
    Superintendent of Documents
    U.S. Government Printing Office
    732 North Capital Street, NW
    Washington, DC 20401
    Dear Mary Alice:
    On behalf of REGIL (Regional Depository Librarians), which represents state, public, research, and academic libraries across the United States, we commend the U.S. Government Printing Office (GPO) and, in particular, the Superintendent of Documents (SOD) for actively considering changes to the Federal Depository Library Program (FDLP) in order to continue to strengthen the Program and improve its long-term viability. In light of this, we also appreciate your solicitation of feedback regarding proposed changes to the administrative rules governing the Program, and we look forward to our ongoing dialogue.
    The proposal put forth by GPO to modify the retention guidelines for Regional Depository Libraries would provide authorization for Regional Libraries to discard tangible depository materials from their collections if the publications (1) have been retained in tangible form for a period of seven years and (2) are available as authenticated and digitally signed files in GPO’s Federal Digital System (FDsys).
    This proposal recognizes that FDsys has achieved a level of stability and security that was envisioned when it was first developed and launched. This recognition is vital to serving our users who have long preferred access to government information in a timely and useable format that electronic information allows. Having government information delivered by an authoritative, centralized source such as FDsys is critical to the success of this proposal. We also agree with GPO’s requirement that Regionals seek permission to replace tangible with digital format to ensure that the “requisite number of tangible copies are retained within the program for access and preservation.”
    As a part of the most transparent and available program in the world, Regional Federal Depository Program Librarians understand the important and vital role we play in the access to government information. Central to this role is providing users access to the US Government’s information and assisting the Selective Depository Libraries in states and regions across the country with the ability to maintain viable services to their users.
    Given the small amount of material that will become immediately available for electronic substitution, we believe there is adequate time to establish policies and procedures while at the same time help Regional Depository Libraries under stress.
    To this end, we want to encourage the SOD to proceed with this proposal. We also see this as an opportunity to continue the dialogue among Regionals, Selectives, and the GPO to better serve the information needs of all of our users.
    Specifically, we request that the SOD work with the FDLP community to strive towards the following goals:
    • By the end of FY 2015 FY (September 30, 2015), that SOD and Regional Depository Libraries establish a mechanism to track and monitor Regionals’ e-substitution decisions so that the effect of the policy change can be monitored
    • By the end of the 2016 FY (September 30, 2016), that FDsys submit and complete a Trusted Repository Audit and Certification (TRAC)
    In turn, Regional Depository Libraries will work with the Selective Depository Libraries in their states and regions to identify libraries which may want some of the materials Regional Depository Libraries have identified as available as a result of e-substitution. These same Selective Libraries will work with their Regional Depository Libraries to identify any benefits or unintended consequences that may not have been immediately known at the beginning of this process. Regional Depository Libraries are acutely aware that there are a few Selective Depository Libraries that may want the opportunity to retain these materials, and we pledge to work with and encourage any Selective Depository Library to increase its service to its state, region, or nation.
    Regional Depository Libraries understand that this policy is offered as a means of providing flexibility and to relieve actual and potential space issues at some institutions and in no way constitutes a requirement that these libraries immediately discard materials without judicious consultations with the Selective Depository Libraries they serve. However, space is an issue at many current Regional Depository Libraries as evidenced by responses to the 2011 Biennial and the 2012 Library Forecast Surveys:
    • The 2011 Biennial Survey, 63% of Regionals (30 of 47) reported that “use of physical space” is one of the “big issues the library as a whole is facing”
    • The 2012 Library Forecast Survey reported that 61% of Regionals (25 of 41) indicated their tangible collections are “cost or space intensive”
    Regionals are also aware that there is some apprehension in the FDLP community regarding the effect this policy will have on the availability of tangible copies. These same individuals have concerns regarding what constitutes an adequate number of copies to serve the public’s need beyond access to authoritative and authentic electronic available text. Regional Depository Libraries view this first step as an opportunity to establish a process, hoping that will determine the potential effects of changes going forward. We also believe that many of these concerns cannot be addressed unless we proceed with this small step.
    Regional Depository Libraries are also encouraged by the future possibility of expanding available collections covered by this policy. However, we also recognize that GPO and the FDLP community must agree on guidelines for including additional digital materials in FDsys, the Catalog of Government Publications, or digital repositories hosted by FDLP members. We anticipate that these guidelines could be developed by the close of FY 2017 (September 30, 2017) and implemented during FY 2018. We believe that many FDLs are already engaged in high quality, standards-based digitization that is, and would be, acceptable to GPO and our users.
    REGIL has polled the current Regional Federal Depository Libraries on the proposal, and as of 5 PM EDT on Tuesday, August 26th, thirty-seven of forty (92.5%) of the Regionals support the proposal.
    In conclusion, the Regional Federal Depository Libraries support this proposal and accept the challenges and opportunity it brings to establish a more electronic Federal Depository Library Program that furthers GPO’s new future and embodies the GPO’s new motto – “Official, Digital, Secure.”

    • Thanks for sending this along Bill. Is it posted on any public site for me to link to?

      The way I see it, this proposed policy only does 2 things: 1) it destroys paper copies which cannot help preservation or access and does so without evidence that it will not hurt both; and 2) it shifts responsibility for preservation and access to GPO without certification or sustainability or succession plan or any guarantee of preservation or access.

      Why, when paper is safe and digital is in danger of being lost (is being lost!) are Regionals willing to a) endanger paper preservation and access? And b) not offering to digitally preserve and provide access for each paper volume they withdraw?

      Why trust that GPO can do everything digital on its own when it already has huge and growing fugitive gaps, and is in constant budget danger (not to mention constant danger of the entire govt shutting down like it did last fall)? How can shifting libraries’ responsibility to GPO be a sustainable model going forward?

  2. Now that REGIL and DLC have waded in, I guess I need to retract my statement about “practicing government information librarians working daily with this corpus.”

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