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GPO’s draft regional libraries report and FGI comments

A few weeks ago, the Government Printing Office released their draft report entitled, Regional Depository Libraries in the 21st Century: A Time for Change? and asked for comments until June 30. I’m not sure how many comments they received, but wanted to publish comments we submitted. Lynne Bradley, Director American Library Association Washington Office, DID submit comments that were endorsed by the Association of College & Research Libraries (ACRL), the Association for Library Collections & Technical Services (ALCTS), and the Government Documents Roundtable (GODORT). GODORT republished Ms. Bradley’s letter on their wiki.

While we are in general agreement with ALA’s letter calling for increased flexibility of Title 44 (*not* wholesale changes in the title) and increased appropriations for GPO initiatives and “regional depository libraries to help offset the costs of storing and preserving government property,” our comments deal with the more philosophical issues embedded in the draft report. Please let us know what you think.

I. Delete from the report all uses of the adjective “legacy” when referring to collections. The use of the word “legacy” as an adjective comes from computer science and is used to indicate things that are “outdated” and “undesirable.” When the report uses the phrase “legacy collections” it implies that it is referring to unwanted and outdated collections. (The report uses “legacy” as an adjective in only one other context: in its reference to sections 1911 and 1912 of Title 44 USC as “Legacy Sections” — apparently in order to define these section as out of date and undesirable.) Thus, the use of the phrase “legacy collections” is either inaccurate and misleading, or imprecise.

In its place GPO should use phrases that accurately describe the collections it wishes to discuss. For example, in place of “legacy collections” the report could uses phrases such as “collections without adequate bibliographic records” or “collections of print materials” or “collections without digital equivalents” or other phrases that accurately describe the collections GPO is referring to.

If GPO does wish to refer to unwanted out of date materials it should describe them that way explicitly rather than use the term “legacy.”

II. The report should more explicitly and accurately address the difference between roles and responsibilities that are legally mandated and those that have been assumed without a legal mandate.

Specifically, we object to the following sentences of the report (Section V.B. pages 16-17) that gloss over these differences. (These sentences refer to Public Law 103-40, The Government Printing Office Electronic Information Access Enhancement Act of 1993.)

The implementation of the GPO Access Act ushered GPO into the online age and accelerated the paradigm shift in the FDLP that changed GPO’s relationship with depository libraries. Regional depositories have the responsibility for permanent public access in the tangible publication environment. In the online information environment GPO has assumed primary responsibility for ensuring content and permanent public access. [emphasis added]

We suggest the following wording instead:

While the GPO Access Act specifically required GPO to “provide a system of online access” and to “operate an electronic storage facility for Federal electronic information,” it did not specify any change in the roles of the depository libraries. It added new roles for GPO, but did not reduce, alter, or delete the roles of depository libraries.

Since 1993, Congress has consistently provided funds to GPO for the “distribution” of government publications to designated depository libraries. This wording was carefully chosen. In 2000 the House attempted to substitute the wording “on-line access” for “distribution,” but that language was rejected.

Nevertheless, GPO has chosen to implement this law in a way that is shifting the relationship between GPO and depository libraries. GPO has chosen to assume responsibility for permanent public access to digital materials and has chosen not to offer digital deposit as an option to FDLP libraries.

This has resulted in a paradigm shift in access, preservation, and service within the FDLP. Instead of relying on FDLP libraries and their different locations, funding, and technological infrastructures, GPO has chosen to implement policies a) that do not “distribute” digital objects to FDLP libraries, b) that make it difficult for FDLP libraries to build local digital collections, and c) that create a preservation system that depends on a single centralized collection with a single funding source.

While these choices seemed appropriate 15 years ago, much has changed over the years. Many libraries are developing institutional repositories and other digital collections. In a survey in August of 2005, 85% of responding FDLP libraries expressed “high” or “very high” interest in being able to “pull” content from GPO and 65% were equally interested in GPO “pushing” digital content to FDLP libraries. In the current survey of Regionals, 52% expressed a willingness to receive digital files on deposit. Commercial and open source software for managing digital collections is now widely available. As we look at new models and roles for FDLP libraries, we need to consider true digital deposit as a viable and important option. We need to look beyond the now-old model of relying solely on GPO having primary responsibility for ensuring content and permanent public access.

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