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Free Government Information (FGI) is a place for initiating dialogue and building consensus among the various players (libraries, government agencies, non-profit organizations, researchers, journalists, etc.) who have a stake in the preservation of and perpetual free access to government information. FGI promotes free government information through collaboration, education, advocacy and research.

The FDLP Historical Collections

A recent question on the govdoc-l mailing list asked if GPO had ever officially defined the term “legacy collection” or “legacy document” and if the definition goes beyond something that has historical value or importance. I posted a short answer there. Here, I document and explain that brief response.

The term was introduced by the Association of Research Libraries (ARL) and by Superintendent of Documents Judy C. Russell in 2003. The phrase has been used almost exclusively in the documents community in the context of digitizing and discarding FDLP historical paper collections ever since.

Before 2003

Before 2003, documents and articles that discuss collections (even in the context of digitizing them) rarely if ever used the adjective “legacy” to describe FDLP collections. For example, a 2002 GODORT report on digitizing government information did not include the word “legacy” to describe the collections to be targeted for digitization.

I did not find any references to “legacy collections” in DttP or govdoc-l or Google Scholar or Library, Information Science & Technology Abstracts before 2003.

2003: Introduction of a New Term

Judy C. Russell, then GPO Superintendent of Documents, apparently introduced the term in late 2003 in an announcement of an agreement between ARL and GPO to “digitize a complete legacy collection.” GODORT mentioned it at ALA in January 2004 and GPO included it in its Strategic Vision for the 21st Century in December 2004.

Russell also referred to “legacy content” at the Center For Research Libraries Forum on “Building Blocks of a National Print Preservation Network.” And, in a 2005 Dissemination Implementation Plan, GPO referred to the “legacy collection of tangible U.S. Government publications held in libraries participating in the Federal Depository Library Program (FDLP).”

Adoption of the term

After 2004, the mentions of an FDLP “legacy collection” increased. Documents librarians adopted the phrase to refer to the paper (and sometimes microform, and, occasionally, even “tangible” digital) documents that GPO had actually deposited into FDLP libraries.

What is the FDLP “Legacy Collection?”

Russell described the “legacy collection” as “tangible items in your libraries” in her remarks to DLC in April 2004. She also said that the legacy collection of U.S. government documents consisted of “an estimated 2.2 million print publications totaling approximately 60 million pages.” A report of the 2004 GPO meeting of experts on digital preservation described the legacy collection as “U.S. government documents currently held in depositories, estimated to be about 2.2 million items (excluding microfiche).”

It is worth noting here that the term was applied to all paper; there was no singling-out of any documents that would have more historical value or importance. The key to inclusion within the definition of “legacy collection” was, apparently, that they were paper and were in FDLP libraries and were targets of digitization (and, as we will see in a moment, targets for discarding).


As noted above, the introduction of the phrase accompanied a plan to digitize the paper FDLP collections. GODORT referred to the initiative as “Digitizing Legacy Federal Documents Collections.” The GPO Strategic Vision described converting “printed legacy documents” into digital format. The Dissemination Implementation Plan enumerated priorities for digitization of the “Legacy Collection.” The purpose of the Experts Meeting was to address digitizing “the entire legacy collection of U.S. government documents.”

The government information community adopted that context along with the phrase. Every use of the phrase that I found was in the context of digitizing paper.

Why “Legacy”?

Why did ARL and Russell choose the term “legacy collection”? Since the use of the phrase was directly and explicitly tied to digitization of those collections, why not describe those collections as “analog materials” or “historical collections” or “paper collections” or even (ugh!) “tangible collections?” Why “legacy“?

The Merriam-Webster dictionary says that the word “legacy” was not used as an adjective until 1990. That use comes not from the libraries but from the computing world. It is used by IT managers to describe software or systems that are outdated and unwanted. Wikipedia says that it is often considered a “pejorative term” and is used to describe systems that are “potentially problematic.” And the New Oxford American Dictionary defines it as “software or hardware that has been superseded.” In practice, IT managers would like to stop supporting “legacy software” and discard it. Sound familiar?

It is, of course, possible that the choice of the term to describe the FDLP Historical Collections was not well thought out and no one intended to imply that the collections are problems that need to be discarded. But it is revealing that GPO’s own 2004 Strategic Vision statement not only used “legacy” to describe “printed documents,” but also said that GPO needed to reduce costs associated with the operation and maintenance of “stand alone, legacy computer systems.” This was not a mysterious, obscure word with an ambiguous meaning — even within the walls of GPO.

Legacy (adj.). Unwanted.

Thus, the use of the term “legacy” as an adjective to describe print FDLP collections reflects a particular attitude (one might even say a bias) about the FDLP Historical Collections. It defines the FDLP Historical Collections as out-of-date, unnecessary, and unwanted. Using this term pre-determines the fate of the collections. Those who use this term are expressly saying that they have already decided that they want to throw the collections away – even if they say that what they want is better access.

Using such terminology helps explain why the discussions about these collections have not focused on their intrinsic value, or their value to specific user communities, or the quality of the digital surrogates being used to replace (not supplement) them. Instead, the discussion has returned to a single question again and again and again: How many copies should we keep? – which is the wrong question.

Digitize and Discard

The phrase fits in well with ARL’s long-term advocacy of digitizing paper collections and then discarding them. See for example its 2008 report in which it proposed “a small number of physical regional legacy collections” and its 2010 report when it recommended that there should be “a distributed system for storage of print legacy collections that involves no more than 15 regionally distributed comprehensive print collections.” These recommendations to discard Historical Collections in order to reduce the number of paper copies in the FDLP are not supported with any evidence that such policies will either meet the needs of our communities or preserve the written record of the government.

Let me be clear. I am not an advocate of saving print collections for the sake of print collections. Tautologies are not useful for planning. But, in the same way, vague promises to enhance access through digitization are also not useful. Vague promises need to be backed up with procedures to minimize the risk of loss of information and long-term planning that provides adequate resources for preservation, access, and service. As James R. Jacobs and I have repeatedly argued (see endnotes), decisions about retention and discarding need to be premised on the needs of our communities and the ability of libraries to preserve and provide free access to the FDLP collections. Just labeling the collections as unwanted and out of date may be a clever way to try to persuade librarians to discard their collections without examining the outcomes of doing so. But labeling without evidence is not an application of Library and Information Science. It is rhetorical misdirection.

Libraries are free to digitize their collections (and they should!). If enhanced access is the goal, this can be done today without unnecessarily discarding a single document. But ARL and their supporters have been adamant that digitization must be linked to “flexibility … for the efficient management of the legacy collections” and reducing the number of print copies by requiring only a “small number of physical regional legacy collections (print and microforms).” And some libraries are using digitization as an excuse and a technique for discarding.

A better term: FDLP Historical Collections

I suggest that librarians use the term “FDLP Historical Collections.”

“Historical” because these documents tell us something about the past. Indeed, these documents are also, in a very real sense, “historic” in that they are the unique official record of our democracy.

“Collections” (plural) because we have many separate collections – not one big one – and we do not have an accurate and complete inventory of holdings across all FDLP libraries that would allow us to call it a single “collection.”

Legacy (noun). Gift, Inheritance.

I think it is fine to use the word “legacy” as a noun when speaking of our historical collections because they have been handed down to us. They are more like a valuable inheritance than an unwanted copy of WordStar. Who will preserve and take care of this legacy? Only FDLP libraries have this as their mission. Only FDLP libraries are responsible for the stewardship of this legacy.

For us to discard those paper publications without ensuring the accurate and complete preservation of the information in them would be to discard a valuable inheritance and ignore our responsibility.


Words matter. Library professionals are supposed to be professional and should be clear and unambiguous when they choose their terminology. This is important when making plans for the future and it is even more important when the planning involves irreversible decisions. Librarians should reject the use of the term “legacy collection” when discussing the FDLP Historical Collections and challenge those who use it.

But choosing a different term is not enough. We should clearly articulate both the inherent value of the FDLP Historical Collections and their specific value to our designated communities.

The documents in the FDLP Historical Collections may not exist anywhere outside of FDLP libraries. Even Judy Russell had to admit that discarding paper collections without a clear preservation and access strategy can be a big mistake. In her remarks to ARL in 2003, Russell said:

Many years ago GPO turned over its historical collection to the National Archives and almost immediately we began to regret the absence of a tangible collection. We have decided to re-establish a comprehensive collection of tangible and electronic documents as a collection of last resort for the program, and the new organization will dedicate staff resources to that effort.

Unfortunately, there has, apparently, been little progress in rebuilding GPO’s paper collection as a Collection of Last Resort. Instead, GPO is actively promoting changes that will make it easier to discard more paper collections.

While individual documents or volumes may exist elsewhere, FDLP libraries have collections that put those individual documents in context of their provenance. Although casual internet users may not understand the value of context and provenance, librarians do (or should) and researchers require it. Before FDLP libraries use digitization as an excuse and a technique for discarding these collections, librarians should insist on several essential criteria. My colleague James R. Jacobs has developed a preliminary checklist in his What Are We To Keep? (FAQ). Let’s think about that checklist and think carefully before we assign pejorative labels to our valuable legacy.


Association of Research Libraries. 2008. Future Directions for the Federal Depository Library Program (Dec 4, 2008).

Association of Research Libraries. 2010. Statement of Principles on the Federal Depository Library Program (October 2010).

Center for Research Libraries. 2004. Building Blocks of a National Print Preservation Network. Focus on Global Resources, Vol. 24, Num. 1 (Fall 2004).

Depository Library Council. 2004. Advice to the Public Printer (January 22, 2004).

Federal Depository Library Program. 2014. Future Roles and Opportunities: An FDLP Forecast Study Working Paper (March 28, 2014).

GODORT. 2002. Report: Digitization Of Government Information. Ad Hoc Committee on Digitization Of Government Information, Cathy Nelson Hartman Committee Chair (June 14, 2002).

GODORT. 2004. First Steering Committee Meeting Agenda. 2004. ALA Midwinter Conference, San Diego, Friday, January 9, 2004.

Jacobs, James A. and James R. Jacobs. 2013. The Digital-Surrogate Seal of Approval: a Consumer-oriented Standard. D-Lib Magazine (2013).

Jacobs, James A. 2015. “An alarmingly casual indifference to accuracy and authenticity.” What we know about digital surrogates. FreeGovInfo (March 1, 2015).

Jacobs, James A. 2015. Legacy collections. “Discussion of Government Document Issues” (25 Jun 2015).

Jacobs, James R. 2014. Why GPO’s proposed policy to allow Regionals to discard is a bad idea. FreeGovInfo (August 27, 2014).

Jacobs, James R., What are we to keep?, Documents to the People (Spring 2015).

Jacobs, James R., What Are We To Keep? (FAQ). FreeGovInfo (April 30, 2015.).

Rossmann, Brian W. 2005. Legacy Documents Collections: Separate the Wheat from the Chaff. DttP: Documents to the People Volume 33, No. 4 (Winter 2005).

Russell, Judith. 2003. Remarks by Judy Russell, 142nd ARL Membership Meeting, 142nd ARL Membership Meeting, Federal Relations Luncheon (May 15, 2003).

Russell, Judy C. 2003. Information Dissemination Operations. Remarks by Judy C. Russell Superintendent of Documents Depository Library Conference/Fall Council Meeting October 20, 2003, Administrative Notes Vol. 24, no. 13 (November 15, 2003).

Russell, Judy C. 2004. Remarks of Superintendent of Documents Depository Library Conference St. Louis, Missouri (April 18, 2004).

U.S. Government Printing Office. 2004. A Strategic Vision for the 21st Century, (Dec. 2004).

U.S. Government Printing Office. 2004. Report on the Meeting of Experts on Digital Preservation. U.S. Government Printing Office Washington, D.C. (March 12, 2004).

U.S. Government Printing Office. Office of Information Dissemination. 2005. Information Dissemination Implementation Plan: Priorities For Digitization Of Legacy Collection. Washington, D.C. (September 15, 2005).

Petition in support of GPO and the #FDLP

An online petition in support of GPO has been created by Suzanne Sears and Starr Hoffman at the University of North Texas. Of most interest is the question at the end of the letter: “If you are a selective in the FDLP, are you interested in working with other selectives in your state to share regional services in the absence of a regional?”

Along these same lines, for your reading pleasure, here’s the running tally of documents surrounding the ASERL Plan for Managing FDLP Collections in the Southeast and the proposed MOU between University of Minnesota Libraries and Library of Michigan/Michigan Department of Education. Please let us know in the comments if there are other documents that should be listed.


Members of the Joint Committee on Printing
William Boarman, US Public Printer
Mary Alice Baish, Superintendent of Documents

We, the undersigned, wish to state our strong support of the Government Printing Office (GPO) in its Congressionally-mandated authority of administrating the Federal Depository Library Program (FDLP), which operates under the specific legal parameters of Title 44 U.S.C. Chapter 19. All government agencies must operate within legal parameters and limited funds assigned to them, and GPO is no different.

While we acknowledge that there are long-standing problems with the FDLP and the Title 44 legislation, we believe that the current administration of GPO is making a concerted effort to rectify these issues while adhering to the current legal parameters. On Thursday, October 20, 2011, the current Superintendent of Documents, Mary Alice Baish, announced a plan to gather information from all libraries currently participating in the FDLP to begin the process of Title 44 reform. Previous attempts at revising the legislation for the FDLP has revealed three factors critical to successful reform: clear vision of what needs to be changed, consensus among the community, and members of Congress who support the legislative changes. The announced plan would be the first step in getting a clear vision of the major issues that need to be addressed according to a consensus of the community.

We understand that the situation that regional libraries find themselves in appears to be dire. Libraries across the nation are suffering from a lack of adequate space, funding, and staff. The responsibilities that Title 44 places on regional libraries are not insignificant. However, they are necessary to ensure a strong FDLP. These responsibilities are crucial to maintain no-fee permanent public access to government information and to ensure geographic distribution of comprehensive collections. Geographic distribution is essential particularly for the guarantee access of individuals with limited connectivity or who live in rural areas.

We fundamentally disagree with the statement that there is no flexibility within the existing FDLP. Any regional library that finds itself unable to fulfill its assigned duties of receipt, retention, and oversight of selective libraries has the option to drop its regional status and become a selective library or drop from the program entirely. The FDLP is designed so that selective libraries may maintain depository status and receive federal documents while being tasked with fewer demands on their space, staff, and fiscal resources. Selective libraries are an integral part of this program and are the face of government information for a wide portion of the U.S. population, particularly in rural areas. Libraries can continue to serve their patrons with the same level of high-quality service and collections whether they are selective or regional. Innovative solutions involving selectives have been successful in sharing regional services within a state, like in Oregon, where four institutions work together to share collections and services to provide regional services for the state.

We are concerned with the number of libraries dropping status, but there has historically been fluctuation within the program. The FDLP has survived these fluctuations for over 150 years. In the 2009 Biennial Survey, only 6 regional libraries indicated they were considering dropping their regional status. If the current economic climate necessitates these regional libraries and others dropping their status, then it will be a lamentable loss to the program and to the nation. However, if the remaining libraries in the program are fully committed to the program then the mission of no-fee permanent public access will still be maintained.

Recent letters and public statements may give the incorrect impression that the entirety of the government documents community is represented by those statements. We believe it necessary to draft this statement of support for GPO and the existing FDLP because our opinions are not supported by the letter signed by 31 of 47 regional libraries or the letters written by major academic library consortia. There are over 1,200 libraries in the FDLP. Some of those libraries are not as well funded, organized, or vocal as the larger academic libraries. This petition is an opportunity for FDLs not represented by those statements to demonstrate our support for GPO in its efforts to continue to lead the Federal Depository Library Program forward into the future.

1. Your Signature and Location
Your Signature and Location Name
Position (optional)

2. If you are a selective library in the FDLP, are you interested in becoming a regional?
If you are a selective library in the FDLP, are you interested in becoming a regional? YesNo

3. If you are a selective in the FDLP, are you interested in working with other selectives in your state to share regional services in the absence of a regional?
If you are a selective in the FDLP, are you interested in working with other selectives in your state to share regional services in the absence of a regional? YesNo

Sears’ response to ARL statement points out inaccuracies #fdlp

We’ve been following with much interest and concern the ongoing and unfolding saga going on between the GPO, Association of Research Libraries (ARL), and Association of Southeast Research Libraries (ASERL) (under the heading “future of the federal depository library program”). This post to Govdoc-l from Suzanne Sears (AUL for public services at University of North Texas and former chair of Depository Library Council) on October 20, 2011 is in response to the ARL Statement on Recent USGPO Decisions Concerning the FDLP dated
October 2011 (released October 12, 2011) and attempts to add context and correct some inaccuracies in the ARL statement.

From: Sears, Suzanne
Sent: Thursday, October 20, 2011 2:00 AM
To: Discussion of Government Document Issues
Subject: RE: ARL Statement on Recent USGPO Decisions Concerning the FDLP

I have been reading over and over the statement released by ARL that Larry so kindly posted for everyone on GOVDOCL and feel strongly that there are inaccuracies in some of the statements that need to be addressed. The following is solely my opinion and not meant in any way to offend anybody, just my concern that some things are not quite right and need to be cleared up.

Point 1 refers to long standing precedent for the approval of multi-state regionals. In the meeting this week, Bernadine Abbott Hoduski spoke on this issue. Prior to 2008, there was no legal opinion on the multi-state regionals. In September 2007, then Acting Public Printer William Turri sent a letter to the JCP seeking approval of the Kansas-Nebraska proposal http://www.fdlp.gov/home/repository/doc_download/49-letter-from-acting-public-printer-william-turri-to-the-honorable-robert-brady. The response letter from the Honorable Robert Brady to Public Printer Robert Tapella in February 2008 http://www.fdlp.gov/home/repository/doc_download/50-letter-from-the-honorable-robert-brady, states that the JCP sought legal guidance on this issue from the Congressional Research Service (CRS). It further states “CRS concluded that neither the language nor legislative history of 44 U.S.C. 1914 supports GPO’s interpretation of the statute. After careful review, the Joint Committee finds the CRS analysis persuasive; if the Public Printer may not authorize shared regional depository libraries under 44 U.S.C.1914, the JCP cannot approve such action.” Now that a legal opinion exists, GPO cannot simply ignore it.

In point 2, there is a quote from Title 44 regarding the authority of Senators to designate regional libraries. Part of that quote is “within the areas served by them.” I am no lawyer, but I do know that Senators serve states, so the areas served by them would be the state that elected them. To me this means that Senators are not authorized to choose a library from outside their state to serve as a regional for their state. This is my opinion.

In point 3, the discussion of regionals and retrospective collections are brought up. The opening third paragraph makes it sound as though the requirement regarding comprehensive collections was decided within the last nine months. This is inaccurate. I served on the Depository Library Council from October 2008-July 2011. In a presentation given by Cindy Etkin at the Fall 2009 DLC meeting, she stated the following “regionals are required to retain what’s distributed to them and there is not an obligation to go back and collect materials prior to when they became a regional? As I’ve shown, it’s been in the guidelines and brought forward; and even as it is today, the regional itself does not have to hold the materials.” She also discussed how the Depository Library Council developed guidelines around 1973 that recommended regionals collect retrospectively. After the meeting, the DLC asked Ric Davis to investigate this issue was it required or just a guideline. We were told during a phone conference call that the Legal Counsel’s opinion was that it was a requirement. This was in 2009, not 2011.

I have to admit that point 4 totally confuses me. I do not understand where the legal opinion that multi-state regionals are not supported in the language of Title 44 precludes collaboration across state lines. GPO encourages collaboration among depositories. The Digitization Projects Registry is just one of the many tools GPO has developed to help foster collaboration between depositories, both selectives and regionals. Although the FDLP community may not be used by everyone, it is an attempt by GPO to bring depositories together to collaborate on topics.

Point 5 refers to “new unfunded mandates and requirements, especially without consultation.” I am extremely confused with this point. I have had discussions with several individuals at the DLC meeting this week and the only thing I can figure out that point 5 is referring to is the new document that GPO released in June 2011 “Legal Requirements and Program Regulations of the Federal Depository Library Program.” This document was released by GPO after consultation with the Depository Library Council. The DLC had been requesting GPO clarify the legal requirements since the Spring 2009 DLC meeting in Tampa. We had heard from the community that the FDL Handbook was too cumbersome to go through to pull out the regulations and that a more compact publication containing only the legal requirements was needed to discuss with our directors and deans. GPO created this document with feedback from the DLC and published it in June 2011. To be clear, these are long standing legal requirements and regulations that have been compiled into a new publication.

My issue with point 7 can be considered more an opinion rather than fact, based on my three years on DLC and my 27 years working with depository collections. I feel that GPO spends considerable time and effort on ways to engage and facilitate partnerships with the community for expanding the digital content. They are restricted in what they can do because of budget and law. They operate within strict legal parameters. For instance, the community has requested that GPO offer grants for digitization. GPO has no legal authority to do so, therefore they can not help in this way. The Digitization Projects Registry is improving due to constant consultation between the community and GPO. It is a tool for libraries to use to collaborate on digital efforts and to avoid duplication of effort.

I do understand the issues facing depositories, both selectives and regionals, regarding their individual institutions needs and the demands on budgets, staffing, and space of a depository collection. Like everyone in the depository community, I am desperate to find a successful solution to these problems to ensure the viability of the program. I am hopeful that the day long discussion Thursday will result in some positive solutions within the framework of Title 44. I want to echo my colleague Dan Cornwall’s statement in his blog “Back from the Brink” http://freegovinfo.info/blog/17, developing a model for the future of the FDLP is going to require cooperation from libraries in the program and GPO. Now is the time we need to pull together and find a common ground for a workable solution. We need to work together to clear up misinformation, rumors, and innuendos that are causing several members of our community to feel personally attacked. As a community, we have disagreed many times over the years on what is the best solution to many problems, but we have never brought it to the point that it is now. I am extremely concerned that the contentious situation we find ourselves in is going to create an atmosphere among Legislators that the program is not worth spending tax payer dollars on and considerably effect the appropriations for vital services like FDSys and the FDLP.


Suzanne Sears
Assistant Dean for Public Services
University of North Texas Libraries
1155 Union Circle #305190
Denton, Texas 76203-5017

ARL Releases Statement on Recent USGPO Decisions Concerning the FDLP

via INFOdocket.com

From an ARL Announcement:

The Association of Research Libraries (ARL) released a statement calling upon the US Government Printing Office (GPO) to reverse its recent, troubling decisions concerning the Federal Depository Library Program (FDLP). ARL asked that GPO approve the University of Minnesota Libraries as the regional for the State of Michigan once it is designated by the relevant Senators, as well as approve and support the ASERL “Guidelines for Managing FDLP Collections in the Southeast Region.” Such actions are consistent with GPO past precedent and, importantly, comply with provisions in Title 44. These types of collaborations and cooperative efforts are essential to the success of the FDLP both now and in the future.

ARL and its members have long-standing participation in and support for the FDLP, a partnership between the Federal Government and libraries throughout the United States that ensures the public has no-fee access to US government information. ARL members invest significant staff, financial resources, and space allocations to the Program with the belief that equitable access to information about our Government and its programs is central to our democracy. Recently, changes in policy and practice by GPO and its failure to embrace needed changes to the Program present serious challenges to the Program’s sustainability and viability. These changes will seriously impact the ability of the public to effectively access government information both now and in the future.

Decisions by the leadership of GPO over the last nine months call for costly changes in practice by federal depository libraries that are not supported by provisions in Title 44, the governing statute of the Program. In addition, GPO leadership has reinterpreted provisions in Title 44 and dismissed long-standing precedent concerning the designation of regional federal depository libraries to the Program. Finally, GPO has not acknowledged current library practice across all types of libraries and has not positioned the Program and its resources to reflect how users engage in digital discovery and access to information.

Read the Complete Statement (2 pages; PDF)

See Also: Background and Primary Documents:
Recent Developments on FDLP as of August 2011 (via ARL)

Docs for Digital Democracy (ARL interim summary)

The Association of Research Libraries (ARL) has released the following 10-page paper:

Documents for Digital Democracy: A Model for the Federal Depository Library Program in the 21st Century, Interim Summary, prepared by Ithaka S + R

It is the top link at http://www.arl.org/pp/access/fdlp/index.shtml