GPO’s Collection Development Plan falls short of the “National Collection”

The Government Publishing Office (GPO) recently released its updated document entitled GPO’s System of Online Access: Collection Development Plan (here are the 2016 and 2018 Plans for comparison) which is “revised annually to reflect content added to govinfo in the preceding fiscal year, in-process titles, and current priorities.” The Plan explains GPO’s designated communities for govinfo, the broad content areas that fall within scope of govinfo, and the various codes — basically Title 44 of the US Code and Superintendent of Documents policies (SODs) — which undergird GPO’s collection development activities. While there is no mention in this document of the “National Collection”, it describes the three major pillars of GPO’s permanent public access efforts as govinfo, the FDLP, and the Cataloging & Indexing program (which produces the bibliographic records for the Catalog of Government Publications (CGP)).

The central part of the Plan is where GPO defines the govinfo collection depth level — defined in Appendix A of the Plan as collection levels modified from the Research Libraries Group (RLG) Conspectus collection depth levels and going from Comprehensive, Research, Study or Instructional Support, Basic, Minimal, to Out of Scope — of the various public information products of the legislative, executive, and judicial branches of the US government.

• Comprehensive level: Congressional resources; current and historic administrative law resources from all executive agencies (by which we assume means legal materials like the Statutes at Large, Federal Register and Code of Federal Regulations); publications of the Offices of the President, Vice President, and Federal Register; opinions of the US Supreme Court, lower federal courts, and special courts;
• Research level: publications from all other agencies of the legislative, executive, and judicial branch as well as those of independent establishments and government corporations (no examples given).
• Study or instructional support level: information products of executive agencies which fall under the purview of the National Libraries of Agriculture, Education, Medicine, Transportation; boards, commissions, and committees; “Quasi-official entities” (those that are not required to publish information about their programs in the Federal Register. Also no examples given).
• Minimal information level: international organizations in which the US government has membership, such as the United Nations.
• Out of scope: publications that are classified for national security or violate privacy concerns.

GPO then explains how it will build the collections in govinfo. Its collection-building activities include direct ingest of current & historical content; digitization and accession of digitized publications from partners including depository libraries; department/agency requests to include content in govinfo; and Web harvest.

Flaws in the Plan

On its surface, the Plan is fine for what it is: a view from 10,000 feet at the various collections in govinfo and a public accounting of GPO’s levels of responsibilities for those areas. But dig a little deeper and the Plan has at least 4 major flaws:

1. Collection development plans are primarily documents for individual libraries, or for specific disciplines within a library. But GPO is not a library. It is at once a cataloger/indexer/publisher/author/aggregator/contractor for 1100+ FDLP libraries which rely on GPO to help them build and maintain parts or all of their federal documents collections and by extension, the “National Collection.” Scoping govinfo vs scoping the “National Collection” are two very different exercises. And not giving the FDLP community a chance to give input and help shape any scoping document weakens how well the document stands on its own.
2. The Plan focuses specifically on providing guidance and determining collection priorities for GPO’s govinfo content management system. But collection development plans are generally aspirational and meant to be system agnostic. They are meant to define the subject, thematic, or topical areas to support their “designated communities” and connect that to the organization’s overarching collection development goals. However, in narrowly defining govinfo’s “designated community” — “staff members in Federal depository libraries, the United States Senate, the House of Representatives, the Administrative Office of the United States Courts, and the Office of the Federal Register” — the Plan only peripherally mentions the various and sundry designated communities of FDLP libraries thereby leaving the very groups served by FDLP libraries outside the responsibility of the Plan.
3. The Plan only partially contributes to GPO’s stated mission of “informing America” (which means a far wider “designated community” than this document scopes out for govinfo). GPO is building the “National Collection,” which to the lay librarian would ostensibly mean having the highest collection depth level for ALL of federal government information. Since their mandate is to “keep America informed” supported by the legislative requirements of Title 44, they should collect comprehensively across the entire government — or at least that should be their stated goal. GPO always says that they are actively and proactively pursuing agencies’ content, but the Plan simply says that GPO will “accommodate any request” by an agency to include their content in govinfo. This is a far cry from the comprehensive “National Collection” — in fact, “National Collection” isn’t even mentioned in the document. Rather than the community assumption that GPO’s mandate is to build and maintain the “National Collection” including all public information products of the legislative, executive, and judicial branches (i.e., everything within scope of the FDLP!) GPO has scoped out a far more narrow and restricted collection development focus for govinfo that does NOT collect comprehensively across the entire government. Our reading of the Plan is that it lacks any aspirations of a bigger vision. It does indeed state that GPO will use its discretion to collect more than Title 44’s specifically required titles (Federal Register, Congressional Record, etc), but it hedges in saying that it won’t go out of its way to get all of the information that the nation needs to be informed. To keep America informed, libraries and the public need a broad, comprehensive collection. This Plan doesn’t generate that; instead it focuses resources on collection activity that most directly support GPO’s primary clientele as the (limited) designated communities for govinfo.
4. GPO explains HOW it will build collections within govinfo. Its collection-building activities include: direct ingest, digitization; department/agency requests to include content in govinfo; and Web harvest. But again, this is directly pitched to govinfo, with no mention of the collection building that takes place in other GPO programs such as Cataloging and Indexing. There’s also no mention of born-digital lostdocs activity as a collection development strategy though there are several GPO working groups currently working on various aspects of lostdocs, and, as we learned during DLC’s recent Fall 2020 conference there is a small, but not insignificant number of documents collected via the lostdocs process (2602 documents cataloged since 2014) (“DLC: Collection and Discovery Services WG – Fugitive Documents 101: Guide to Lost Federal Documents.” Thursday October 22, 2020, 4:45 – 5:30). In short, the Plan mentions only some of the tools GPO has available to build collections on behalf of the FDLP.

Conclusion and recommendations

The 1100+ FDLP libraries justifiably look to GPO as the central hub in the FDLP wheel. They expect GPO to do everything they can to facilitate the building and maintenance of the “National Collection.” FDLP libraries assume that everything within scope of the FDLP ought to be collected comprehensively. If there are areas of the “National Collection” where GPO feels that it can’t or doesn’t need to act — because of budget, lack of legislative mandate, etc — they should state that (and they have stated that where the National Libraries of Agriculture, Education, Medicine, and Transportation are concerned). But GPO should also state that those areas ARE in fact part of the “National Collection” and GPO should in fact do everything within their power, budgets and staff to bring those areas under bibliographic control — whether that’s actually collecting or aggregating metadata from other government archives and National Libraries.

GPO’s System of Online Access Collection Development Plan should be seen as part of a constellation of documents that deserve attention from the entire depository community, on behalf of the public. It is one piece of a policy pie that determines GPO’s priorities for the “National Collection,” and scopes out where GPO is prioritizing content for long-term access and preservation in all of its systems of online access. Because this strategy does not extend to all of GPO’s collection activities such as Cataloging & Indexing, Web archiving, partnerships, Lostdocs reporting, etc., it is essential that libraries have a part in discussing and responding to these priorities. FDLP libraries must work together to actively collect the many parts of the “National Collection” that GPO cannot develop, maintain, and preserve on its own. FDLP libraries are NOT irrelevant to the growth, maintenance, and preservation of the “National Collection.”

The GPO System of Online Access Collection Development Plan should therefore be discussed and agreed to by the entire community. The Plan should contain agreed-upon aspirations and strategies for long-term preservation of (and access to) the wider repository of federal information in which libraries have a part, especially in those areas where GPO has relinquished the responsibility to collect comprehensively. This means that FDLP libraries will have to stop being passive and start actively pursuing everything that GPO has demonstrated they can’t or won’t. To “keep America informed,” libraries and the public need a broad, comprehensive collection in physical, digitized, and born-digital formats. This Plan doesn’t generate that on its own; instead it only focuses resources on collection activity that most directly support the (limited) designated communities for govinfo.

In short, libraries and GPO need to collaboratively work out and agree to the aspirational building of the National Collection, and that starts with an open conversation and agreement on defining policy documents like a Collection Development Plan for the “National Collection.” And libraries need to get together and work on those areas that GPO is abdicating. We need a movement to supplement/complement what GPO is not willing or able to do. It is up to FDLP libraries and librarians — in collaboration with GPO for sure — to make a reality the building and maintenance of the “National Collection.”

As always, we welcome readers’ comments on the Plan as well as our analysis of the Plan and suggestions and recommendations moving forward.

Authors:
James A. Jacobs, University of California San Diego
James R. Jacobs, Stanford University

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