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DLC responds to open letter regarding the new Regional discard policy

On December 18, 2015, a group of 16 librarians wrote an open letter to GPO regarding the implementation of the new Regional discard policy (here’s more on our coverage of the regional discard policy). The letter asked a series of questions that the signatories felt would need to be thought about — if not answered — to inform the test phase of the policy, questions needed to evaluate the new policy’s effects and effectiveness.

One month later, there has been no response from GPO. There was, however, a response on January 6, 2016 posted to govdoc-l by the Depository Library Council (DLC). We include the full text of that response below.

Dear James et al. – On behalf of the Depository Library Council, I would like to offer a response to your Open Letter to GPO of December 18th, 2015 regarding the new regional discard policy. While we agree that there are many questions that need to be answered in order to implement the policy and evaluate its effects and effectiveness, we expect that the outcome of the implementation testing phase will clarify the requirements and restrictions of the new regional discard policy. Therefore, we ask that for now, the community hold its questions and comments until after the implementation testing phase is complete. Council has requested that GPO report back to the community on the results of the implementation testing before the policy is implemented in its entirety. On our end, Council is committed to devoting as much time as is necessary at the Spring Virtual DLC Meeting in late April to allow GPO to report on their progress and to allow the community to ask questions. We have also asked that GPO expedite their response to Recommendation 1 from the October Depository Library Council Meeting and Federal Depository Library Conference that addresses many of these very issues (see below).

I would like to emphasize that Council is in no way trying to discourage members of the community from asking questions or initiating discussion about the new regional discard policy. As this new policy stands to have a profound impact on the future of the FDLP, it is essential that it be thoroughly vetted by all members of the community before it is fully implemented. We simply ask that GPO be afforded the opportunity to focus on the implementation testing phase and work with the six regional depository libraries who have agreed to participate rather than be pressured to try to answer questions for which they may not yet have answers. The results of this test phase should give GPO the opportunity to provide informed rather than speculative answers to our questions and will undoubtedly result in a far more productive conversation.

Perhaps the most important aspect of this new policy is that it very clearly demonstrates that GPO is listening and responding to concerns raised by the depository community and especially the regionals, particularly those that are struggling to retain their regional status. Having worked closely with GPO on the new regional discard policy, Council can safely say the GPO has routinely solicited input and proceeded with an abundance of caution in bringing it to fruition; we feel confident that they will continue to do so well beyond the policy’s eventual implementation. As the advisory committee to the Director of the Government Publishing Office and the Superintendent of Documents, Council will continue to offer advice and recommendations on the regional discard policy and, once the implementation testing is completed, will make sure that the community has ample opportunity to do the same. Until then, we ask that everyone keep an open mind and give GPO a chance to do its work.

Hallie Pritchett, Chair
Depository Library Council

Depository Library Council Recommendation 1
December 11, 2015

Council congratulates GPO on having received approval from the Joint Committee on Printing to allow regional Federal Depository Libraries the option to withdraw tangible depository materials from their collections, provided they have been retained by the regional library for a minimum of seven years and are available on FDsys in authentic, digitally-signed formats. For those regionals that are struggling with space, staff, and/or funding shortages, this new regional discard policy may well be the difference between retaining regional status and becoming a selective depository library, or even dropping out of the program entirely. More importantly, it sends a very clear and much appreciated message to Council and the depository community at large that GPO is listening and responding to our comments and concerns.

Council further commends GPO for choosing six regional depository libraries to participate in implementation testing starting in January, 2016 to test regional discard processes and procedures. We expect that the outcome of the implementation testing phase will clarify the requirements and restrictions of the new regional discard policy. However, we would like clarification on the requirements regarding titles held by selective depository libraries if those titles are discarded by their regional. Specifically, Council would like to know whether regionals will be required or at least encouraged to pursue a Selective Housing Agreement (SHA) with one or more of their selectives as part of the regional discard process. While we do not feel that the lack of an SHA should prevent regionals from discarding materials that meet the established criteria, pursuing an SHA may help ensure that a sufficient number of tangible copies are retained in a particular geographic area or region.

Finally, Council asks that GPO report back to the community on the results of the implementation testing before the remaining regional depository libraries are allowed to implement the regional discard policy at their institutions. This would allow the libraries participating in the implementation testing to share their experiences with their fellow regional coordinators. Council asks that an update on the implementation testing be presented at the 2016 Spring Virtual Depository Library Council Meeting. Once the implementation testing is complete, we ask that the written report be released in conjunction with a webinar to allow the community at large the opportunity to ask questions and provide feedback.

Jim and I responded to DLC on govdoc-l, respectfully disagreeing with Council’s suggestion to ask questions only after the end of testing. We believe that now is the time to ask questions. As Jim stated, “…the policy may have a profound impact on the future of the FDLP, but it may also have a profound impact on the preservation of the information that FDLP libraries uniquely hold and the access to that information that our communities rely on us to provide. That is why we asked simple, empirical questions whose answers must be known in order to evaluate the eligibility of those titles for discarding.”

We believe that these kinds of empirical questions need to be asked in order to test the implementation of the policy. We see no harm is asking GPO to share the answers with the community and no reason for GPO to withhold the answers. Asking these questions beforehand, and knowing the answers will help the community understand the issues that the testing is meant to address and help GPO and the community evaluate its effects and success. Though we do not speak here for the 16 signatories — all of whom are experienced government information librarians and library administrators with a commitment to a 21st century FDLP — they clearly thought so as well.

We’re glad that Council recommended that GPO report back to the community and look forward to the 2016 Spring Virtual Depository Library Council Meeting when the community can judge for itself.

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