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Now that GPO is
testing the implementation of implementing the Regional Discard Policy, it is time to finally get answers to the important questions that GPO has not addressed over the last two years.
Although we have asked many questions about this policy, our concerns boil down to one simple question: Will FDLP — and more importantly, the public! — lose information when Regionals discard their historic collections? To answer that question, we just need to know if GPO’s implementation of the Policy will ensure that the paper preservation copies of discarded volumes and their digital surrogates are complete and accurate.
We now know that the implementation will not prevent loss of information.
In October 2015, GPO announced that it would begin testing processes and procedures of the new Regional Discard Policy with six regional depositories in January of 2016. GPO provided little description of how the policy would be implemented beyond the policy itself, leaving many important questions unanswered.
GPO has now provided links to three draft implementation documents, a recording of an information webinar, and some other “informational resources.” This provides the FDLP community with the first indications of how GPO is interpreting its new Policy and how it intends to implement it.
There are still many unanswered questions, but we now have the first solid indications of how GPO intends to balance preservation of (and access to) the FDLP Historical Collections while discarding them.
We analyzed GPO’s earlier implementation statements in a previous post. We also asked specific questions about implementation in an open letter to GPO, and, in a separate post, we review the few answers to those questions that we can infer from this new batch of documents.
In this post we focus on the big picture and the most important things FDLP librarians need to understand about GPO’s implementation of the Policy.
In December of last year, sixteen librarians wrote an Open Letter to GPO regarding the Regional Discard Policy in which we asked twelve questions about the approved version of the Regional Discard Policy.
Now that GPO has released several new “informational resources” about progress of the “testing phase” (now referred to as “implementation phase one”) of the implementation process, we have some answers to some of those questions.
More than half of the open letter’s questions focused on one of the five titles originally slated for use during the testing phase, the “GAO Reports and Comptroller General Decisions” (GAO/C-G). We chose that collection because it is a relatively small and well defined collection and is easily browsed on FDsys. It provided an easy opportunity to address broad questions with specific examples.
GPO has now released a new and growing spreadsheet list of titles eligible for discard (strangely dated September 2016!) that includes four of the original five test titles, but not the GAO/C-G collection. So, several of our questions that were specific to those reports remain unanswered and, as far as we know, unaddressed by GPO. Many of the “answers” that we now have to our questions are preliminary because GPO has not addressed them directly. Rather, what we have below is what we can glean and infer from a series of policy documents and draft procedural documents released by GPO in July.
Below, we list the answers we infer from the new documents released by GPO. In a second post, we further analyze and go into the details of what we’ve learned from those documents and the reasoning behind the inferences below.
On December 18, 2015, a group of 16 librarians wrote an open letter to GPO regarding the implementation of the new Regional discard policy (here’s more on our coverage of the regional discard policy). The letter asked a series of questions that the signatories felt would need to be thought about — if not answered — to inform the test phase of the policy, questions needed to evaluate the new policy’s effects and effectiveness.
One month later, there has been no response from GPO. There was, however, a response on January 6, 2016 posted to govdoc-l by the Depository Library Council (DLC). We include the full text of that response below.
A group of government information librarians have written an open letter to the GPO Superintendent of Documents asking questions regarding the implementation of the new regional discard policy. Below is the text of the letter. We will also post GPO’s answers to these important questions here on FGI.
Dear Superintendent of Documents Mary Alice Baish, (cc Depository Library Councilors and signatories of this open letter),
We the undersigned write to you as engaged librarians. As GPO goes into a test phase for the new Regional Discard Policy, there are a host of questions that will need answers both in order to implement the policy and in order to evaluate its effects and effectiveness.
We are hoping that GPO will commit to open and transparent implementation procedures during the test phase.
With this in mind, we are sending this open letter to pose a few basic questions that we hope will help this process. We plan to publish this open letter as well as GPO’s response on Free Government Information (FGI), but we hope that GPO will also post the information on FDLP.gov and provide a space there for other interested parties to make suggestions, ask questions, and get answers about the policy.
We begin with questions about how GPO defines some of its own requirements. We follow those with more specific questions about one of the series slated for use during the testing phase: the “GAO Reports and Comptroller General Decisions.” (We chose the title/series “GAO Reports and Comptroller General Decisions” because it is a relatively small and well defined collection and is easily browsed on FDsys. There is a description of the collection on FDsys here. There is a list of the items in the collection here.)
GPO has said that, to be eligible for discard, a title must have been retained by the regional for seven years, and that a digital copy must be “available on GPO’s Federal Digital System in a format that meets the standards of the Superintendent of Documents as authentic with the digital signature of the Superintendent of Documents.”
- What formats currently qualify as meeting the standards of the Superintendent of Documents? PDF? PDF/A? Other?
- If a title in FDsys only has a digital file in plain text format, will it be eligible for discard?
- Will digital copies have to be certified by the Superintendent of Documents with a PKI certificate issued by VeriSign?
- If not, what other form of “digital signature” will make a title eligible for discard?
- In the GAO/C-G collection on FDsys, will titles that have a plain text digital copy but no PDF copy be eligible for discard? (See for example: 1992 Bank Resolutions: FDIC Chose Methods Determined Least Costly, but Needs to Improve Process, GAO/GGD-94-107, May 10, 1994.)
- In the GAO/C-G collection on FDsys, will titles that have only a text file without full text be ineligible for discard? (See for example: 1992 Thrift Resolutions: RTC Policies and Practices Did Not Fully Comply With Least-Cost Provisions, GAO/GGD-94-110, June 17, 1994. “We regret that the full text of this item is presently unavailable.”)
- Have all the different kinds of reports listed within the GAO/C-G collection on FDsys been cataloged in the CGP and deposited in FDLP Regionals? (The kinds of reports include: Briefing Report, Chapter Report, Comptroller Decision, Comptroller General Decision, Correspondence, Fact Sheet, Letter Report, Oral Presentation, Other Written Product, Staff Study, and Testimony.)
- What is the overlap between deposited GAO/C-G titles and titles in the GAO/C-G collection on FDsys? For example, are there titles that were deposited that are not in FDsys?
- How many titles in the GAO/C-G collection on FDsys are in the qualifying format?
- How many titles in the GAO/C-G collection on FDsys currently have the appropriate “digital signature”?
- Does GPO intend to add digital signatures to documents in this collection that do not yet have them?
- How many of the titles in the GAO/C-G collection on FDsys are eligible for discard now?
We look forward to hearing from you at your earliest convenience and continuing our discussions about the future of the FDLP.
Bernadine Abbott Hoduski
Tara Das, Government Information Librarian, Lehman Social Sciences Library, Columbia University Libraries
Martin Halbert, Dean of Libraries, University of North Texas Libraries
Stephen M. Hayes, Entrepreneurial Spirit Endowed Business Librarian, Dir., Thomas Mahaffey, Jr. Business Library, Acting Depository Librarian, former Depository Library Councilor
James A. Jacobs, Librarian Emeritus, University of California San Diego
James R. Jacobs, Government Information Librarian, Stanford University
Kris Kasianovitz, Government Information Librarian, Stanford University
Lawrence R. (Larry) Meyer
Suzanne Sears, Assistant Dean for Public Services, University of North Texas Libraries
Robbie Sittel, Government Information Librarian, Head, Eagle Commons Library, University of North Texas Libraries
Linda Spiro, Government Information Librarian, Rice University
Jill Vassilakos-Long, California State University San Bernardino
Sinai Wood, Associate Professor & Documents Librarian, Baylor University
GPO’s new Regional Discard Policy and GPO’s recent presentations about it are full of hopeful words and good intentions. We applaud GPO for having good intentions and high hopes, but we question if the Policy can meet those expectations.
- Introduction of the Policy and its Implementation
- One definite Goal. Some questionable objectives
- Preservation of and Access to Paper Copies
- Next steps
Here is what you need to know about the Discard Policy. GPO’s caveats and assurances about the new policy aside, there will no longer be any Regional Depositories for documents more than seven years old. It removes the requirement that there be access paper copies of all documents in the FDLP. It weakens the FDL Program by continuing the shift of responsibility away from FDLP members and toward GPO. It does not increase flexibility (as advocates of the policy claim), it shifts flexibility away from Selectives and gives it to Regionals. It puts new burdens on Selective Depositories. It establishes a new model for the preservation of paper copies of documents that is undocumented, unproven, and risky. It ignores long-term implications in favor of short-term benefits to a few large libraries. It makes GPO’s “guarantee” of long-term, free access to government information nothing more than a hollow promise.
We believe that the Policy actually weakens the FDLP and damages both access and preservation. We believe that the Policy provides no guarantee of meeting those expectations, and will make it more difficult to do so. Below, we explain why.
At the Fall Depository Library Council (DLC) meeting, GPO gave a general outline of how it will proceed to allow Regional Depository Libraries to start discarding paper copy documents.1 GPO has, so far, provided the following information about the Policy itself and how GPO intends to implement the policy:
- Government Publications Authorized for Discard by Regional Depository Libraries [draft policy, 07/09/2014]
- Vance-Cooks, Davita. [letter (July 10, 2015) from GPO to Gregg Harper, Chairman Joint Committee on Printing (JCP) requesting approval of policy to give regional Federal depository libraries the option to withdraw tangible depository materials]. and Harper, Gregg. [letter (August 5, 2015) to GPO] Both documents in one PDF file here.
- Council Session on Discards audio recording and presentation slides (10/20/2015)
For additional background, links, and commentary, see: Information sharing and the National Plan by Shari Laster.
The new policy has only one stated goal: To allow regional depository libraries the option to discard paper copies of government documents.2. To be clear, this is not a substitution of one format for another, like microfiche for paper. Regionals will not be required to uphold their Title 44 obligations to “retain at least one copy of all Government publications either in printed or microfacsimile form.” (44 U.S.C. §1912).
In addition to this specific goal, GPO has expressed a variety of objectives, which it apparently hopes the new policy will help accomplish. But GPO has been both inconsistent and vague in its expression of these objectives and how it will actually implement the policy.3 Six Regional Depositories will participate in a test of the policy in early 2016; presumably, this will produce more implementation details.
Some of GPO’s objectives (such as giving Regionals “the ability to expand their capability to serve the increasing number of remote users” [Vance-Cooks]) can be accomplished without the new policy.
Most of the objectives relate to giving Regionals the “flexibility” to discard paper copies of documents. GPO does not claim that this will have any positive effect for users. On the contrary, GPO acknowledges that regionals that are already relocating tangible collections to offsite storage are impairing the goals of the FDLP.4 GPO implies that Regionals will use resources that will be freed by discarding documents “to focus on the needs” of users of government information [Vance-Cooks]. But GPO does not specify what the resources are, or explain how it expects freed space to be reallocated to services or collections for users of government information, or require any such reallocation. Furthermore, some Regionals have admitted that any savings brought on by this policy will not go toward public service of government information, but will go toward their library’s central operating budget. Since the Policy does nothing to further such objectives, we should not read them as objectives of the Policy but as wishes of GPO.