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One year later…what’s happening with Regionals and discards?

In April 2014, GPO presented a draft policy (also known as an “SOD” or “Superintendent of Documents Public Policy Statement”) that would create a mechanism for Regional depository libraries to request permission to substitute specified tangible holdings for authenticated electronic holdings in FDsys. FGI has already responded in detail to this proposal (see “Why GPO’s proposed policy to allow Regionals to discard is a bad idea”).

Library associations and organizations also published letters in response to the proposed policy. As FGI has documented (see “Library associations weigh in on GPO’s proposed policy to allow Regionals to discard”), both those supporting and opposing this policy outlined steps that GPO should take so that the FDLP can continue to meet its obligations for permanent access to the national collection of U.S. government information. Given that many of these projects will be the focus of updates at the upcoming 2015 DLC Meeting and FDL Conference, I want to summarize what information we have so far on GPO’s activities as they relate to some of these recommendations and suggestions.

GODORT Recommendations

In its letter dated August 18, 2014, GODORT requested that GPO take four major steps prior to the adoption of any policy allowing Regionals to substitute electronic versions of authenticated publications hosted on FDsys.

  1. GPO and the FDLP community should jointly develop a national inventory of historical federal publications held in depository libraries.
  2. GPO and the FDLP community should use a research-based approach to making decisions regarding the appropriate number of tangible copies of a publication needed for access, re-use, preservation, and re-digitization.
  3. FDsys should undergo the Trusted Repository Audit and Certification (TRAC) audit process.
  4. GPO should adopt a quality assurance (QA) process for digitized and born-digital publications made available for substitution.

(Full disclosure: along with James R. Jacobs, I was a member of the group that drafted GODORT’s response letter, and I was also a member of the Steering Committee that voted on the final letter.)

Some of these steps are within the scope of GPO’s National Plan for Access to U.S. Government Information, as presented at the April 2015 Depository Library Council virtual meeting. More specifically, some of these are components of the Federal Information Preservation Network (FIPNet).

National Inventory

At the December 2014 virtual meeting of the Depository Library Council (DLC), GPO presented an overview of the National Bibliographic Records Inventory Initiative (NBRII), a cluster of projects within GPO’s Library Services & Content Management (LSCM) unit intended to expand the bibliographic and serials holdings records included in the Catalog of Government Publications (CGP). These projects include transcription of the historic Monthly Catalog and GPO shelflist, internal records conversion from older GPO systems, cooperative cataloging projects, and the identification of fugitive documents. Both cooperative cataloging and fugitive document collection are identified as potential roles for FIPNet partners. This year, GPO is also participating in the annual Federal Libraries Bibliographic Record Analysis conducted by the Library of Congress.

Within the National Plan, developing and maintaining “an inventory of preservation copies of record” is an action item included to help make the national collection accessible to future generations. Such an inventory would only document retention commitments, not national holdings, and the infrastructure for this inventory is as yet unspecified.

Externally, a project is underway at HathiTrust to build a metadata registry for all U.S. government information. This resource is primarily intended to identify digital surrogates, not tangible holdings, but will provide valuable information about what else could be out there.

Number of Copies

While other organizations responding to the draft policy requested clarification or made specific suggestions about defining “requisite number of copies” as stated in the language, GODORT called for wide discussion and research prior to the identification of any minimum or threshold number of copies for a given publication.

A session at the April 2015 virtual DLC meeting, entitled “Preservation & Access: Framing the ‘How Many’ Question,” focused on the context of this question. In the issue brief accompanying the presentation, four Council members (including FGI colleague Daniel Cornwall) described three major obstacles to identifying a number of publications needed for preservation for any given title.

  1. In order to determine how quickly copies of a publication ‘decay’ out of the program through loss, withdrawal, damage, or other factors, accurate data on historical and current holdings would be needed. For a variety of factors, this data may be difficult or impossible to find.
  2. Knowing the rate over a given period of time provides little insight into the rate going forward because we have no reason to believe it’s a fixed rate.
  3. The national collection is both large and diverse, making meaningful sampling a challenge.

James R. Jacobs has argued at length that this is asking the wrong question. In his essay “What are we to keep?” he states:

For me, even thinking about answering [the question of how many copies to keep] raises more questions. How can we know how many copies to keep unless we specify the purposes for which we wish to keep them? What are those purposes? How will we know if we are meeting our goals? How will discarding paper benefit users? How can we be sure that we are not losing information when we discard paper copies if we do not have an inventory of the paper copies that exist? How can we implement a policy that is so vague that it doesn’t define things like “a requisite number of copies,” and how decisions will be made, and which apparently treats a born-digital XML document created by GPO and an indifferent digitization without OCR text and missing its maps and foldouts as of equal value?

If a target or threshold number of copies for a publication were identified, it seems possible and perhaps even likely that the population of that particular publication would drop precipitously as libraries would make local collection management decisions that de facto assign responsibility for their users’ long-term access to a network to which they do not meaningfully contribute.

Trusted Repository Audit

Library associations and organizations joining GODORT in calling for GPO to pursue a formal audit of FDsys included ALA, AALL, ASERL, ARL, and REGIL. GPO Director Davita Vance-Cooks had previously committed to this process, and it is well underway. In the July/August 2015 issue of FDLP Connection, GPO announced the appointment of a National Digital Stewardship Resident to “review of GPO documentation, workflow, and business practices against the metrics specified in the ISO 16363:2013 Trusted Digital Repository (TDR) standard for the audit and certification of trustworthy digital repositories.”

Quality Assurance

The GODORT letter referenced the “Digital-Surrogate Seal of Approval” (DSSOA) proposed by James A. Jacobs and James R. Jacobs as one model for a quality standard that any official digital surrogate designated as an authentic U.S. government publication should meet. Additionally, GODORT requested that GPO conduct a gap analysis and correct any omissions in FDsys collections that would be eligible for Regional substitution.

GPO continues to add authenticated content to FDsys, and follows the technical guidelines of the Federal Agencies Digital Guidelines Initiative (FADGI). While GPO has announced its intention to ingest content digitized by libraries into FDsys, a comprehensive set of guidelines for this process is not currently available. The topic of future ingest of materials into FDsys has a large and wide-ranging impact on the proposed SOD because it could bring more materials under the umbrella of the policy and have a direct impact on the preservation of historic documents.

Other Recommendations

The responses from library organizations included requests for clarification as well as proposed changes or additions to the policy. In attempting to summarize these responses, I saw a substantial degree of variety.

Some of these are roughly in agreement with each other, while others are not. For example, both ALA and AALL simply requested clarification on the requisite number of tangible publications, whereas ASERL proposed that a very small number should be identified for the purposes of this policy. Both AALL and ASERL called for a transparent decision-making process for granting permission to substitute, while REGIL suggested that GPO publicly track the permissions that are granted. It is impossible to evaluate the extent to which these and other suggestions have influenced GPO’s current position on what would be included in any policy submitted for consideration to the Joint Committee on Printing, because no revised draft has been circulated for discussion.

However, setting aside recommended revisions to the policy itself, there are several additional recommendations in conjunction with the draft policy that came from library organizations. These include:

  • Expand the scope of authenticated materials in FDsys and add content from outside sources to the scope of this policy (ASERL, ARL).
  • Provide incentives for expanded participation of Regionals committing to print retention (ASERL, ARL).
  • Expand agreements with federal agencies for long-term print retention (ASERL).
  • Continue to pursue external partnerships for preservation of born-digital materials, including FDsys content (AALL).

To one extent or another, these four recommendations are provided for in the structure of FIPNet. While these can all be seen as positive goals, it should be noted that expansions to authenticated FDsys content also expands the inventory of publications that could be eligible for Regional substitution someday under the proposed SOD, resulting in a decrease in tangible publications available for access (and eventual re-digitization). Also, given ASERL’s call for a very small number of “requisite copies” identified by the policy, the third point seems to be a call for GPO to continue to outsource the preservation of tangible documents from the FDLP to other entities.

One last recommendation deserves a brief mention:

  • Support a non-governmental repository (specifically, HathiTrust) as an official supplementary access point (ASERL)

While there is no indication that GPO is formally considering such a step at this time, it should be noted that a substantial percentage of the scans in HathiTrust would not currently meet FADGI standards for quality, or DSSOA standards for usability.

What’s Next?

As of this writing, no public action has been taken in moving the SOD forward; however, the National Plan as presented in April 2015 includes an action item to implement the draft Regional depository discard policy. More specifically, this is an action item for Principle #2 (“Government has the obligation to disseminate and provide broad public access to its information”), with the outcome that “[t]he FDLP will have a governance process and a sustainable network structure that facilitates efficient management of operations, collections, and services.”

We can expect to have more updates and clarifications on these projects at the DLC Meeting in October.

Selected Bibliography

Depository Library Council. “Finding and Using Gov Data, Preservation and Access [Preservation & Access: Framing the “How Many” Question].” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated April 30, 2015.

GODORT Rare & Endangered Government Publications Committee. “Summary of discussion: preserving federal government information panel discussion.” http://wikis.ala.org/godort/images/8/8a/REGPFIPnetsummary2015.pdf.

HathiTrust. “Creating a registry of U.S. federal government documents.” https://www.hathitrust.org/usgovdocs_registry.

James A. Jacobs and James R. Jacobs. “The Digital-Surrogate Seal of Approval: a Consumer-Oriented Standard.” D-Lib Magazine, Mar/Apr 2013, vol. 19, no. 3/4, http://dx.doi.org/10.1045/march2013-jacobs.

James R. Jacobs. “Library associations weigh in on GPO’s proposed policy to allow Regionals to discard.” http://freegovinfo.info/node/9118. Updated September 12, 2014.

James R. Jacobs. “What are we to keep? thoughts on the National Collection (DttP Spring 2015 feature article).” http://freegovinfo.info/node/9936. Updated April 30, 2015.

James R. Jacobs. “Why GPO’s proposed policy to allow Regionals to discard is a bad idea.” http://freegovinfo.info/node/9073. Updated August 27, 2014.

Library Services & Content Management. “GPO’s National Digital Stewardship 2015 Resident.” http://www.fdlp.gov/all-newsletters/archive/view/listid-1/mailid-631-volume-5-number-4. Updated August 26, 2015.

Library Services & Content Management. “The national plan for access to U.S. government publications.” http://www.fdlp.gov/project-list/national-plan. Updated August 10, 2015.

Library Services & Content Management. “National Bibliographic Records Inventory Program.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated December 8, 2014.

Library Services & Content Management. “The University of North Texas: First Federal Information Preservation Network (FIPNet) Partner.” http://www.fdlp.gov/all-newsletters/archive/view/listid-1/mailid-631-volume-5-number-4. Updated August 26, 2015.

Office of the Superintendent of Documents. “Government Publications Authorized for Discard by Regional Depository Libraries [Discussion Document].” http://www.fdlp.gov/file-repository/about-the-fdlp/superintendent-of-documents-policy-statements/2501-discussion-document-sodpps-regional-discard. Updated July 9, 2014.

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


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