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FGI’s comments and recommendations for the GPO draft report of the task force on an “all-digital” FDLP
[editor’s note 10/28/2022: we updated the text below about 100% of govinfo being published digitally in order to clarify where we got that number and why we use the 100% number rather than the 97% born-digital that is most frequently cited.]
We want to thank GPO Director Halpern for calling a “Task Force on a Digital FDLP” and for all of the members of the task force for diligently working through the many thorny issues regarding the future of the Federal Depository Library Program (FDLP). Director Halpern has requested public comment on the draft report until October 14, 2022. We at FGI are submitting the following as our public comments.
1. The task force was asked to study “the feasibility of an all-digital FDLP.” The group was charged to define the scope of an all-digital depository program and recommend how to implement and operate it.
Although the task force working groups concluded that the FDLP can and should go “all-digital,” the draft report was also consistent in noting that “all digital” does not mean everything will be available only in digital formats (pp. 7, 10). The final report should emphasize this point and clarify and clearly state that print remains a viable format for some of our most important government publications as well as an important access method – and recommend exploring future print opportunities like “print and distribute on demand” as an option for depository libraries.
2. The draft report has lots of good ideas but we suggest that some clarifications and reorganization will bring the findings and recommendations of the different working groups into better focus.
We suggest that the final report should begin with a clear “problem statement” that the report will then address. We suggest that this should have two points:
- Currently 100% of government Public Information is published digitally. (We are extrapolating that 100% estimate from table 11 of the 2018 Library of Congress study “Disseminating and Preserving Digital Public Information Products Created by the U.S. Federal Government:A Case Study Report” which showed that only three of the surveyed agencies reported less than 100% of their publishing output was born-digital. This 2018 estimate is no doubt closer to reality for most agencies than the 2009 estimate of 97%.)
- Only a small fraction of that born-digital government information is currently being curated or preserved in any regular fashion. This has created an enormous preservation (and, therefore, long-term access) gap. Any “all digital FDLP” must recognize and address this enormous digital preservation gap.
(Note: We base this on the research we have done examining the contents of GPO’s Govinfo repository and 2020 End-of-Term crawl data. We found that the great bulk of new digital Public Information is produced by the executive branch (90% of all government PDFs (aka “publications” on the government web are published by the executive branch), but only 2% of the born digital PDFs in GPO’s Govinfo repository are from the executive branch. Meanwhile LC’s web harvesting is relying on GPO and NARA to take care of the executive branch [https://www.loc.gov/acq/devpol/webarchive.pdf] and, by law, NARA is treating all executive branch web content as “records,” of which only 1-3% are typically preserved. For some more details, see our post “Some facts about the born-digital ‘National Collection'”.)
These two points would put the Task Force’s recommendations into context. The primary focus of actions designed to ensure “permanent no-fee public access to digital content” must focus on ensuring the preservation of that content. No digital system can ensure “access” unless that system has control over and preserves the content it intends to make accessible.
3. To address the problem statement, we recommend that the report create long-term goals from which all recommendations would flow. It would be persuasive and most helpful if the Task Force provided explicit connections between each recommendation and one or more of the goals, showing how the success of each recommendation can be evaluated in terms of the goals.
- Increase the preservation of all federal government Public Information.
- Ensure permanent, no-fee access of federal government Public Information to the general public.
- Enhance discoverability and usability of federal government Public Information for all.
4. We believe that the draft report minimizes the need to preserve the existing national print collection. It emphasizes digitization of paper documents for access and accepts and proposes even looser rules for the discarding of paper collections without adequate safeguards for the preservation of the information in those collections in either paper or digital formats. Digitizing for the sake of better access is a noble objective, but preserving the born-digital content that is currently NOT being curated and in danger of loss is a much more urgent matter than enhancing access to already well-preserved paper collections.
5. We suggest that the final recommendations and action items be grouped or labeled in categories that will clarify their purpose and scope. For example:
- principles (free access, privacy, etc.)
- short term tasks
- long term objectives
6. Earlier this year we created a list of some specific long-term strategies which may be of use to the Task Force: “FGI’s recommendations for creating the ‘all-digital FDLP'”.
By reorganizing and refocusing the report on what is truly important — preservation first, access built on preserved content — the report will be clearer about the current status of preservation and access and how GPO and FDLP can contribute solutions to existing gaps and weaknesses.
James A. Jacobs, University of California San Diego
James R. Jacobs, Stanford University