FGI’s comment on GPO’s draft policy on preservation (SOD-PPS-4-2026)

GPO has asked for comments on its draft of a new version of its policy statement SOD-PPS-4-2026, “Permanent Public Access to U.S. Government Public Information through Preservation” which will supercede SOD-PPS-2016-4 (effective July 5, 2016). Unfortunately, the comment form had a 4000 character limit, so below is FGI’s complete comment.

This policy implies that there are difficult challenges to preserving government information and expands the potential scope of what GPO wishes to preserve but puts much of the burden of responsibility on current and future “partners” without providing a strategy for preservation by those partners. The policy promises the world but provides no strategy for delivering on those promises.

The good news

The policy contains two positive improvements over the last version of this policy (SOD PPS 2016-4) which bring the policy up to date with existing GPO actions. The first improvement is the explicit commitment to certification of its GovInfo.gov content management system and repository under the ISO 16363 Trustworthy Digital Repository standard and the CoreTrustSeal standard. (GPO obtained ISO 16363 certification in 2018, and CTS certification is 2024.) This is significant because these certifications ensure that the details of GPO’s digital preservation procedures for its GovInfo repository are publicly available and consistent with international preservation standards. These include GPO’s Memorandum of Understanding (MOU) with the National Archives and Records Administration (NARA), which designates NARA to serve as a contingency and successor for GovInfo.

The second improvement is the definition of the scope of preservation to include all “Federal Government public information.” This is significant because GPO’s legal mandates and its interpretation of them have been limited in the past to the US Code Title 44, Chapter 19 definition of “Government Publications” and the Office of Management and Budget (OMB) Circular No. A-130 definition of “Information Dissemination Products.” Those definitions were narrower and limited what GPO targeted for preservation. Use of the term “public information” (which GPO adopted in its 2020 proposal for revision of Title 44) reflects the US Code definition of “any information, regardless of form or format, that an agency discloses, disseminates, or makes available to the public.” This is important because it removes the past restrictions that have limited the scope of what GPO could target for preservation. (For more on this, see Jacobs and Jacobs, Preserving Government Information: Past, Present, and Future. 2025)

The promises

The policy deletes those actions which GPO deems no longer important to its preservation activities and asserts in their place the general statement that GPO has the responsibility to “preserve and ensure public access to the National Collection of U.S. Government Public Information for future generations.” It expands the scope of the FDLP by defining the “National Collection” as a “geographically dispersed collection of the corpus of Federal Government public information.” It further promises to make this complete corpus freely accessible. This is an exhaustively ambitious goal.

The strategy

The policy lists two specific actions that GPO will undertake: 1) it will continue to maintain GovInfo; and 2) it will hire a preservation librarian who will lead a preservation program that will “address the preservation needs of the digital and tangible content of the National Collection.”

GPO’s direct responsibility for preserving Public Information and making it accessible is through its GovInfo repository and website. But the policy fails to acknowledge that only about 2 percent of the packages in GovInfo are from the executive branch, which produces about 93 percent of all federal government Public Information (see Jacobs and Jacobs, 2025). How will GPO address that enormous gap in preservation?

Apparently, GPO will rely on various kinds of partnerships for preserving what GPO does not. These partners are vaguely listed as “Federal agencies, and other institutions with Government publications,” “official hosting partners,” “preservation partnerships,” NARA, and FDLP libraries. While leaving the responsibilities of other partners vague, the policy says that FDLP partners are responsible for “tangible Government information that is within the scope of the Federal Depository Library Program (FDLP) and the Cataloging & Indexing (C&I) Program.” The policy does not specify any strategy for recruiting or managing other partners. Neither does it mention any preservation or access standards for these partners. It fails to provide a strategy for how content spread over many partners will be integrated into the “National Collection.” There’s no mention of succession planning for any “official” digital content hosted by GPO partners.

Except for GovInfo, the policy fails to provide a strategy for collecting, acquiring, storing, describing, and preserving the “National Collection” or for making that Collection accessible and useable by the public. It does not mention that the Designated Community of GovInfo is not the general public, but librarians and government employees.

The policy does mention a “mandate” for the C&I program to provide “comprehensive indexing to tangible and digital Government publications,” but it refrains from describing how that program will scale to encompass all federal Public Information. (Between 2005 and 2021 C&I created about 19,000 records a year (Jacobs and Jacobs, p.67) and in FY2024 added only 11,000 new cataloging records to the CGP (FY 2024 Library Services & Content Management (LSCM) Year Review p.26).

The policy does not explicitly mention the relatively new concept of the four National Collection Service Areas (NCSA’s) or the preservation stewards program meant to bring current and historic physical depository publications within GPO’s preservation program. There’s also no mention of the “Print Distribution Titles List” (which lists the small number of titles that will continue to be printed and distributed by GPO) or how any of these new concepts support GPO’s preservation program.

The new draft deletes the stated requirement of regional depository libraries to provide permanent public access to their depository materials. So, the regional concept that came into being with the Depository Library Act of 1962, which assures geographically distributed access and preservation, is for all intents and purposes no longer required of the program although the law still mandates it.

The policy replaces the current policy’s description of and requirement for collection maintenance with a general statement about “employing lifecycle management and preservation best practices” and the need for preservation and maintenance. Although the wording is not explicit, it seems to imply that “tangible” collections will be “maintained” and digital collections will be “preserved.”

There is no mention of or responsibility for the content that falls within GPO’s defined scope of the “National collection” (which includes everything published by the US government) but that falls outside of the control of GPO and/or its official partners.

Conclusion:

A policy should describe the particular problems or issues that the policy is meant to address and state how the organization will positively work toward alleviating those problems and issues. Unfortunately, this proposed policy update of the 2016 SOD on preservation does not do that.

It is clear from this updated policy that GPO is committed to the digital stewardship vision of GovInfo. Maybe GPO thought that it was enough that this preservation policy update positively asserts that the agency has a responsibility “to preserve and ensure public access to the National Collection of U.S. Government Public Information for future generations” and that it will have a preservation librarian on staff to lead its preservation program – and that all of the devilish details do not need to be expressed in this policy statement. But there is a lot that is left out which leaves us wondering – despite the positive assertions regarding the preservation of public information – how GPO will maintain and expand its preservation program and how its preservation program will be applied to both print and digital content going forward.

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