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COL’s FDLP Task Force Survey and FGI’s responses

[updated 4pm 1/7/14. I clarified a couple of statements. JRJ]

Last summer, the ALA Committee on Legislation (COL), Federal Depository Library Program (FDLP) Task Force released its FDLP report and recommendations. In response, FGI wrote a white paper “Wait! Don’t Digitize and Discard! A White Paper on ALA COL Discussion Issue #1a”. While agreeing with much of the report’s recommendations (avoid duplicative efforts, digital deposit etc), we took issue with some points and tried to unpack and give context to the problems and assumptions put forth by the task force.

COL asked the FDLP task force to continue for an additional year and their first order of business is an FDLP survey to gather input and feedback to “outline a process for ALA to bring together diverse opinions and to guide the Committee in its future consideration of policies in relationship to the FDLP.” While the survey was sent out to ALA divisions and round tables for official feedback, I think it important that ALL librarians with an interest in government information submit answers to the FDLP survey. Please submit your survey responses by February 14, 2014.

Also, please consider attending the COL meeting at ALA Midwinter on Saturday, January 25 from 10:30-11:30am in the Convention Center, room 107B.

Lastly, in the interest of public discussion, I thought our readers would be interested in seeing the 20 survey questions beforehand and our survey responses. Below are all the questions (starting with #3 as questions 1-2 are demographic) in bold as well as our submitted answers.

A comprehensive preservation plan includes digital documents supplemented with preserved tangible collections with a yet-to-be-determined number of full print collections, in controlled environments and in geographically dispersed locations. — NAPA report “Rebooting the Government Printing Office: Keeping America Informed in the Digital Age”

Identification of Materials – in order to implement a preservation plan, it will be critical to outline a process for identification and processing on the national level. This collaboration will require the broad participation of libraries, commercial and not for profit organizations, agencies, and associations.

3. Do all tangible materials within the FDLP need to be preserved?


I worry that this question is ambiguous and will result in a variety of answers which could too easily lead to misleading interpretations. To try to get around the ambiguity, let me say that I believe that there is no FDLP information that should be discarded or abandoned.

The community might well want to identify specific copies or editions or versions or formats of any given specific information content that need no longer be preserved because the information content is being approrpriately preserved. But, to do that, we need an accurate accounting of what information content exists, how many copies we have, the physical state of such materials, etc.

I would suggest that format (“tangible” or other) is not a useful criterion for selecting materials for preservation or discard. I would also suggest that information that exists only in paper copy should be preserved and, further, that every such work (edition?) should be preserved.

4. Realizing that not everything can be preserved immediately, what should be the process for determining the priority plan?

Is this question about “digitization” for preservation? Paper collections are being preserved now under long-time FDLP rules and procedures. If we’re talking about actual preservation, born digital should have priority.

I think this question may be confusing and conflating “digitization” with “preservation” and “historic” with “born-digital.”

Digitization of historic/paper publications, while providing better access, does not necessarily contribute to their preservation and digitization for preservation does not necessarily guarantee better (or any) access. For example, many publications that are scanned — e.g., those going through the google books project — are disbinded and destroyed without any guarantee that the digitization process has necessarily accurately or completely preserved the original content. Further, “digitization” encompasses a wide range of activities and digitizations may or may not meet quality standards for long-term preservation and use.

Also, many born-digital federal documents are arguably *more* in need of preservation action than paper documents — since paper documents are ostensibly already being preserved via the FDLP. The reason for this is that there is a single steward (such as a government agency) that has sole responsibility for preservation and access of those files and the files are therefore at risk of intentional or unintentional, poltical or bureaucratic or financial decisions that will lose or alter or discard that information.

I believe that any preservation plan and prioritization policy needs to have in place a process and framework for preserving an adequate number of physical paper copies as well as a process and framework for collecting, describing and preserving digitized paper and born-digital publications.

As for prioritizing what to digitize (in a NON-destructive manner!), I would give higher priority to those publications that have NOT been widely distributed or have not received any or adequate cataloging.

I would suggest that we should develop a number of criteria for determining priorities, not just a single criterion. For example, we might want to identify different categories of paper materials for digitization: some (plain text in a uniform format on good paper with clear print) are easier (and cheaper) to digitize more accurately, some (statistial publications, odd format publications, color and illustrated publications, older publications with thin paper/bleed-through print/etc., publications with non-uniform layout and fonts, etc.) are harder (and more expensive) to digitize accurately and completely. Setting priorities for diitization could take such a categorization into account along with other factors (condition of the paper copy, completeness and acuracy of existing metadata, known number of complete copies in paper and known number of complete paper copies needed for preservation-of-the-content (as opposed to simple access to the content), known number of paper copies needed for access, decisions about intent of digitizations (access, preservation, image-only or image+text, or image+text+reformatting (e.g. xml, tei, epub…?)…

Please read the following for more on these issues:

5. Who should be involved in preserving FDLP materials? GPO, FDLP libraries, commercial, and/or not for profit organizations?

GPO and FDLP libraries — with assistance from non-profits like the Internet Archive (which actually has official status as a library!) — should be the primary actors in any plan for preserving public domain government publications. Any digitization plan MUST include an agreement that digitizations will be freely and publicly available without subscription or fee and in DRM-free formats.

While commercial outfits may have experience in this area and may be consulted, I would strongly recommend against including commercial entities in any long-term preservation plan. Not only are commercial entities disinclined to do anything that does not support their bottom line, it goes against the spirit of the FDLP for public domain materials to be taken out of the public domain and only made available in subscription databases and/or commercial products. There is already ample evidence of private companies contracting with federal agencies to digitize content that is then privatized and taken out of the public domain to the detriment of the public who owns that information. See:

Preservation Methods – the processes for digitization and preservation are varied and some digitization is not necessarily preservation. There are a variety of projects that may contribute to a national preservation plan. The Task Force report affirms that there should be multiple locations and geographical distribution.

6. Is digitization a preservation standard or does it serve as a discovery/access resource or both?

“Digitization” is not a standard but a generic term that encompasses many different processes and procedures and can result in many different results of varying quality and suitability for different purposes. Even poor quality digitizations can be preserved, but that does not qualify them as “digital preservation” of the original information. “Digitization” is also only one step (the first step: creation) of a number of steps that would need to be taken (ingest, storage, data management, preservation and preservation planning, discovery/access/delivery, and service) in order to either provide access to or preservation of the digital objects created by any given digitization process. “Digitization” is, therefore not a useful concept on its own to address preservation or discovery or access.

To better address this question one needs to specify how an item will be digitized and for what purposes it will be digitized and develop an evaluation of the process to be used to determine if the output of the digitization meets the requirements.

Typically, today, most digitization projects (particularly large-scale projects) aim to provide access (not preservation) to page-images of the original books. Those scans — e.g., google books — offer pretty good (but not great) discovery (try and find a specific volume of any digitized serial in GBP and you’ll see what I mean about “pretty good” discovery), but many of the scans are of poor quality, with inaccurate or no OCR, blurred images and missing pages etc.

As we look to digitization as a process, we should evaluate what we want from that process and develop projects that match those goals. We should develop more projects that aim higher than simple access to digital images that are no better than (and, in some cases, not as good as) the original books. We should develop projects that would envision the possibilities of digital information, not just pictures of static information. This would include digitization that would enable reformatting the content for current and future devices and uses. All digital objects are born-digital objects. Perhaps most importantly, treating digitization of paper as no more than a surrogate for the original paper with no more functionality than the original is short-sighted at best and destructive at worst.

As noted earlier, there are various and varied levels of digitization. Even publications which are digitized to the highest current *digitization* standards should not necessarily be relied on as a copy of last resort. Without adequate attention to the unique qualities of individual documents, the digitizaiton may not fit the needs of all users and some users will continue to need access to paper publications. For example, the images of large size and color documents and documents with maps, tabular data and inserts may be less-usable than their paper originals.

7. Should there be different standards for copies – more rigorous for congressional materials and less for pamphlets for example?

NO. decisions about use of standards should not be made based on format of the original. Such a choice would imply that all pamphlets are less important to everyone forever than any congressional bound volumes, for example. this would be making an unwarranted judgement on the quality of content based on format and an unfounded judgement on the value of the content to unspecified users of the future.

Digitizations of paper should be undertaken to address needs of user communities of the future as well as the present. Short-term cost savings should not drive library decisions if it impedes long-term access, preservation, or usability of the information content. It is reasonable to assume that any publication that is worth scanning should be scanned at the highest quality standards that will lessen the likelihood of its needing to be re-scanned as digitization technologies continue to get better and user needs evolve.

8. What is the role of Regional FDLP libraries in preservation centers?

Regional FDLP libraries should be seen as the first best option in any preservation plan. Geographic distribution of both paper and digitized/born-digital publications will continue to be a necessary part of any plan going forward and regionals are best equipped to offer those services since they’re already set up and working. ALL regional libraries should be required to participate in or designate one library in their region to participate in LOCKSS-USDOCS as part of their depository responsibilities. This would fall under the current FDLP shared housing agreement concept.

Trusted Partners – the FDLP has a partnership program and the Task Force report notes that partnerships could be a critical component of a national preservation plan.

9. What are the qualifications of a trusted partner?

A trusted partner, at least in terms of digital preservation, is one that is built on OAIS principles, has a succession plan in place, and is not driven primarily by the profit motive. Consortia and other library-centric organizations should be seen as trusted partners as long as preservation AND free public access are inherent parts of their missions.

10. Can commercial and not for profit entities be considered a trusted partner?

Commercial entities will probably disqualify themselves as trusted partners if adqueate definitions of responsibility are in place; trusted partners should provide long-term, free public access and have a succession plan in place to describe what happens if they ever choose to break the partnership. So, in general, commerical entities will probably NOT be relied on as trusted partners as their missions are, by law, motivated first by profit rather than by public access, public service or information preservation. Non-profit entities can be trusted partners as long as preservation and public/free access are inherent parts of their missions.

11. What current initiatives exist that can contribute to partnerships? (LOCKSS and other initiatives).

FDLP libraries themselves, LOCKSS-USDOCS, Internet Archive, ASERL’s COE libraries, library consortia…

Registry and Identification – the FDLP has initiated a registry for digitization (http://registry.fdlp.gov) and this might be the basis for a preservation plan. The Task Force notes that cataloging tangible and online materials is still a critical component for any national efforts in discovering and accessing FDLP and other government information.

12. How should individual cataloging efforts be coordinated?

via GPO and the catalog of government publications (CGP).

13. How should commercial entities be incorporated with library efforts?

Commercial entities provide a useful and welcome *complement* to free public access entities — but they should never be seen as a substitute or replacement for free public preservation, access, and service.

Commercial entities should be encouraged to donate metadata toward the national registry and/or digitization projects. They should also be encouraged to deposit their content in collaborative archival services like LOCKSS-USDOCS for safekeeping.

Any national catalog (OCLC, CGP) which has links to publications in subscription services (e.g., Proquest Congressional database) should also include links to freely available digital copies.

14. What additional cataloging/identification projects exist that might contribute to a national effort?

Hathitrust registry of US federal government publications, ASERL collections of excellence, Internet Archive digitization efforts (be aware that IA has a complete set of historic Congressional publications (serial set, Congressional record, hearings etc) garnered from the N&O list a few years ago. They are just waiting for funding to digitize).

Broadening Expertise – in a distributed, electronic world of information, FDLP libraries are able to assist non-FDLP libraries and FDLP resources are more integrated with commercial information resources. The Task Force considers this an opportunity and challenge that will impact librarians and library workers regardless of type of library.

15. What are the professional development needs for librarians and library workers who may utilize FDLP information?

This growing idea that “all librarians are now documents librarians” really bothers me. It makes for a good bumper sticker, but are “all librarians engineering librarians”? Government information is a very specific area within LIS — which happens to touch on many subjects and disciplines — with specific and iteratively-built skill sets and knowledge base. Having a government information librarian on staff is critical to a library’s success in serving it’s community. Just as we shouldn’t expect all librarians to have in-depth knowledge of every subject and discipline, and shouldn’t expect every librarian to be a cataloger, and we shouldn’t expect all librarians to have in-depth knowledge of the workings of government and its information resources. At the same time, I have heard that a disturbingly large number of LIS programs are deprecating if not completely doing away with their government information curricula.

With that in mind, the documents community should first survey LIS programs to see what’s being taught, what are the requirements, what are the % of students taking government information courses, and whether or not LIS programs are *using* government information in their classes (no copyright!) for digitization, digital and physical preservation, indexing/discovery, text-mining, etc?

The documents community — as well as ALA as the accrediting organization! — then needs to create a model curriculum and require that ALL MSLIS programs have courses on government information to provide all librarians with basic familiarity about the FDLP program itself, FDSys and the FDLP core collection as well as basic knowledge of government information resources and collections at all levels of government at a minimum.

Within the documents community, there needs to be continuing education opportunities — that are open to ALL librarians — but for librarians to expand their govt information expertise and broaden their technological skill sets so that they’ll have at least a basic understanding of digitization, digital collection development, and other technologies to help them do their work in serving their communities. There needs to be more of “accidental government information librarian” webinars, but also in-person workshops similar to ICPSR’s 5-day workshops on data services.

Library administrations also need to be more supportive of the need for govt information librarians to travel to conferences (GODORT, DLC, etc) as that is where we learn from our colleagues and move the entire field forward.

16. How can expertise be spread to all librarians beyond FDLP designated librarians?

Every FDLP library ought to:

–reach out and make contact with other FDLP- and non-FDLP libraries in their area.
–Arrange viewings of GPO trainings for libraries in their city. There have been some very good ones.
–Consider site visits or virtual office hours for library staff at their institutions and around their cities.

Depositories ought to blog their reference questions. GIO chat service (http://govtinfo.org) should do that as well. This “seeds the cloud” and allows librarians and the public to more easily find government information resources.

Documents librarians should put in proposals to their state conferences.

Local GODORT chapters ought to consider emulating North Carolina’s Accidental Docs Librarian webinar series.

Government information librarians should have ongoing workshops within their own libraries.

17. How can core competencies related to government information be developed for all librarians?

See 15 and 16.

I believe GODORT is already working on core competencies within the GODORT Education Committee. The 21st Century Government Information initiative on WebJunction might be another place to look for core competencies.

The American Library Association has a vested interest in the development of skills, services, and advancement of the FDLP program. ALA’s role is to assist and support librarians and library workers who work with government information. ALA’s expertise contributes to national discussions and government policies and ALA can provide assistance in bringing together a variety of partners to advance a common goal.

18. How can ALA assist in the development of an FDLP preservation plan?

Adopt the Digital Surrogate Seal of Approval (DSSOA) and encourage individual libraries to do the same for their digitization projects. ALA can facilitate a national discussion and inventory of government documents. ALA can also advocate for a “government information librarian in every library” as a way to further the goals of a preservation plan as well as ongoing collection development and public service to library communities of all shapes and sizes.

19. How can ALA work with other association and entities to advance an FDLP preservation plan?

Lobby Congress for appropriate levels of funding and against long-term privatization of digital access. No cost should be for taxpayers, NOT agencies. Reach out to other organizations on the need for an FDLP preservation plan. Argue strongly for the continuing need for both local collections AND government information librarians in every library. Also advocate inclusion of historic government publications in consortial shared storage projects like the Western Regional Storage Trust (WEST).

20. What future actions should ALA pursue to advance an FDLP national preservation plan?

See #19. Sponsor (or help produce sponsorable projects) to investigate the digitization challenges of a heterogeneous collection such as FDLP’s and investigate the preservation, access, and usability requirements for the long term for such collections.

Accept that digitization is probably not the best approach for PRESERVING tangible documents. Consider microfilming or geographically dispersed high density storage facilities of last resort. ALA should prioritize preservation measures for born digital materials which seem to be decaying quickly through link rot.

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