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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.

FGI response to Ithaka draft values proposition for the FDLP

We’ve just sent our comments/analysis of the Ithaka S+R “Modeling a Sustainable Future for the Federal Depository Library Program in the 21st Century: Value Proposition” to the project staff and would like to share our comments with the community. Ithaka S+R are still accepting comments so get over to the fdlpmodeling.net site for access to all of their draft documents and leave comments. And by all means, feel free to leave comments, suggestions and ideas for us here as well. We’ll share those comments with the Ithaka S+R staff.

Ithaka S+R Value proposition: the missing pieces. A Response to the Ithaka S+R “Modeling a Sustainable Future for the Federal Depository Library Program in the 21st Century: Value Proposition”

Focus on Libraries, not users

The draft “Value Proposition” report from the Ithaka S+R “Modeling a Sustainable Future for the Federal Depository Library Program in the 21st Century” project focuses explicitly and exclusively on the value of the Program to participating libraries, not on its values to users. It assumes that if the Program is of value to participating libraries, it will have value to the public.

[T]his value proposition focuses on considering the costs and benefits of participation in the FDLP from the perspective of a participating (or potentially participating) library under this new Direction and various new Models. While we recognize and celebrate the value that the Program offers to the American public and various specific communities, that value is only discussed here insofar as it contributes to the value proposition of a library. Ultimately, structures that offer positive value propositions encouraging libraries to take on a wide range of roles and responsibilities in support of the overall mission of the Program will directly support the interests of the American public in long-term, no-fee access to government information and support for its effective use. On the other hand, a Program that does not consider the value propositions perceived by the libraries that are expected to serve in critical roles runs the risk of the failure of both the Program and its ability to support the needs of the American public. (p. 3)

Thus, rather than building a Program that has value to users, it proposes trying to build a Program that has value to libraries in hopes that they will participate and that their participation will somehow have a trickle down benefit to users. In fact, any value proposition MUST take users into account because library administrators heavily weight gate counts, circulation statistics, and other user measurements as bases for library policies and budgetary decisions.

We believe that this logic has three fatal flaws:

First, the draft report’s focus on the value to libraries results in a skewed and even misleading understanding of the history and future of the FDLP. In the report’s description of the value of the FDLP, it repeatedly uses the phrase “many libraries.” This phrase implies that there is either a consensus among libraries, or demonstrable trends in one particular direction, or a consistent motivation for changes to the Program. But neither this report nor the earlier FDLP Modeling draft reports document any such consensuses or trends or motivations. If anything, the reports document the diversity of motivations in the FDLP community. In fact, this use of the phrase “many libraries” masks the existence of other views of the value of FDLP. The report tells the story of the historical value of the FDLP from only one perspective — that of participating libraries and, more specifically, from the perspective of library management (i.e., “What does my library get out of participating in FDLP?”). This narrative of the value of FDLP to libraries is plausible as far as it goes, but it is seriously incomplete. There are other narratives that are as important if not more so.

A different narrative, from the point of view of users, for example, would tell a completely different story. It would tell how libraries have helped users find and use government information and have ensured the preservation of that information. It would tell the story of how users are happy today with the access they have to government information on the web directly from agencies. It would also provide a librarian’s view of the future of free public access for users and compare the benefits and risks of different models. Such a narrative would illuminate what the different models would actually mean to users, rather than to library managers. Among other things, it would demonstrate the need for building many user-focused services supported by and integrated with specific, user-focused collections. It would result in models that benefit users. Participating libraries would benefit because they would be providing useful services to users.

Second, it is not clear that the individual Roles will actually provide any benefit or value to participating libraries. In fact, the report does not even examine the costs and benefits of the Roles, but focuses instead on the Models, which are comprised of Program-oriented broad areas of activity (“Building Blocks”) that are implemented through library-oriented Roles. In addition, the descriptions of the Roles in the Models draft report do not adequately define what “participation” in the FDLP Program will mean. It blurs the lines between FDLP libraries and non-FDLP libraries, and between FDLP libraries and libraries that have specialized, non-Title-44 responsibilities. In short, the Values Proposition does not clearly articulate how FDLP participation will provide any benefit over non-participation, or if any of the roles will provide any real value to any libraries. (For more on Building Blocks, Roles and Models, see our previous comments on the draft models report).

Third, this approach does not address the biggest issue facing FDLP libraries today: the disintermediation effect of the Web. As documented by the Ithaka S+R Environmental Scan and as repeated in the Values report, users do not see the need for — and are not using — libraries as intermediaries to government information. Users are largely happy to search the open Web or go directly to government web sites to get government information. In this context, if participating libraries do not provide demonstrable benefits to their users, no amount of libraries reducing costs and adopting most of the report’s Roles (reducing their responsibilities, or drawing down their collections, or unbundling their commitments) will persuade users that libraries are a necessary or useful part of their information seeking and using process.

The Models should, indeed, consider the “value propositions perceived by the libraries,” but they should do much more. By focusing on the possible value to libraries of ill-defined “participation” in a Program that does not define its value to users, the Value Proposition fails to demonstrate that it will be either sustainable or effective.

The missing piece: Digital Collections

Although the Ithaka S+R reports go further than any previous analyses of the FDLP in finding value in digital collections and in proposing ways to ensure their long-term preservation, the reports still overlook the value of digital collections to participating libraries, to their users, and to the Program. And, the reports assume — wrongly in our estimation — that collections and services can be usefully separated.

The Values Proposition report undervalues the importance of digital collections by implicitly adopting several assumptions that GPO promulgated for many years and that most libraries have, until recently, accepted or at least tolerated. These assumptions are: that “tangible” collections are the only collections that provide value to libraries; that digital collections do not provide value to individual libraries; that services and collections can be separated; and that “access” is as good as “ownership.” As more and more libraries are building digital collections or contemplating doing so, and, as GPO has recognized that FDLP libraries can be essential partners in digital preservation, these assumptions embedded in the Values Proposition are increasingly anachronistic and simply false.

The “unbundling” of collections and services that the draft reports recommend emphasizes the separation of these activities. We believe the final Modeling report would be stronger if it emphasized the need for combining these activities. Such combinations could be done collaboratively by libraries working together or by individual libraries, but they cannot be done successfully if service providers do not have direct control over a collection and how it is built, organized, and presented.

The reports do modify these assumptions in one important aspect. They explicitly understand the need for long-term preservation and the importance of (a few) libraries in this role. The draft Values Proposition report does not, however, see any value of smaller libraries (or many libraries) having digital collections and perpetuates the idea of a few libraries handling the bulk of the work. This changes the FDLP from a distributed, participatory system to a centralized, hierarchical system. (For more on this issue, see our comment on the FDLPModeling site) This assumption can be seen most clearly when the report describes the “historical” benefits of participation in the Program:

The declining perceived value realized from tangible government materials combined with the increasing perceived costs of the responsibilities of maintaining these collections poses a complex dilemma for many participating libraries. (p. 5)

[I]t is increasingly clear that the exclusivity once enjoyed by depository libraries as the sole venue for accessing government information has largely disappeared. The increasing ability of the average American to access [digital] government information without the intermediary of the depository library has left some depositories questioning the value that they realize by building and maintaining tangible collections of government information. Although the provision of free tangible copies of government information is intended to be one of the core benefits of participation in the Program, many libraries no longer view this as a particularly compelling incentive to participate. (p. 6) [emphasis added]

In the above passages, the report blurs the distinctions between digital and “tangible” information and between access and ownership. This results in the implication that, if “tangible” collections are no longer of value to libraries, then digital collections must not be of value either. This is another fatal flaw of the report.

We believe that, if digital government information were deposited with FDLP libraries, those libraries would gain from building digital collections many of the same kinds of value that they secured when they built paper collections. And, not only libraries would benefit. There are at least four kinds of value that would result from digital deposit.

First, users would gain. Users would benefit if libraries of all sizes addressed the needs of their specific user communities by building digital collections that included authentic, deposited, digital government information along with other digital information. By building such collections, libraries could provide for their user communities (regardless of geographic proximity) rich, unique collections of information from many sources, combined in a common user-interface, augmented by tools for discovery and use, customized for those collections and users. Users would find it easier to locate and use information that best matched their needs, regardless of its original producer or distributor. Rather than having to search for “all” information using generic search engines, or search for information by producer using agency-specific search engines, users could use rich content-specific tools designed and optimized for specific, preselected, quality collections. Additionally, with more libraries building more digital collections, libraries would leverage the inherent nature of the open Web in order to make digital government information more findable. This “seeding the cloud” approach would help users find government information in the same way that links to and from Wikipedia articles and YouTube videos result in higher Google search ranking and thus better findability of information.

Second, libraries would benefit. Participating FDLP libraries would have a digital resource that other libraries would not have: authentic, officially-deposited collections that would comprehensively match depositing criteria. By building digital collections of public domain information, the libraries would have a valuable resource for data mining, text indexing, and other computational research. By combining Title-44 materials with non-Title-44 materials, libraries could build unique collections that no other library or agency (including GPO) would have — collections designed for their relevance to specific user communities. By developing unique tools for discovery, access, and use, FDLP libraries could provide resources and expertise that would contribute to and enrich the digital-library community at-large and gain reputational benefits within that community.

Third, the Program would benefit. By encouraging and enabling FDLP libraries to maintain collections of Title-44 digital materials, GPO could more securely guarantee both preservation of and access to those materials. By building online tools that would enable users to easily acquire government information from any of a number of digital libraries seamlessly and transparently, GPO could better ensure long-term, free access even if GPO itself becomes unable to do so. By facilitating the building of a network of digital repositories, GPO could better ensure the long-term preservation of authentic, unaltered copies of Title-44 material. By facilitating the building of collection-specific and user-community-specific tools, GPO could enhance access to Title-44 materials far beyond what it could provide on its own.

Fourth, the Library Community would benefit. Every library, not just FDLP libraries, will benefit from having a strong community of digital libraries providing enhanced access and services for government information and rich, unique collections. Government agencies would also fit in this broad category of beneficiaries to the extent that they are like libraries in providing content and services to users.

Even though the report articulates the need for some libraries to participate in long-term preservation, by ignoring the value of digital collections to libraries and users, it reduces the opportunities for a more sustainable, effective Program of service and collections.

A different kind of Value Proposition

We propose instead a different kind of value proposition. We strongly recommend that Ithaka S+R expand its values proposition to examine the benefits to users and the Program, as well as participating libraries. In addition, we suggest that the final report should examine value the way some economists do: by examining the aggregate benefit across all stakeholders. The final report should examine how the Program could maximize this overall social benefit. The final report should ask if changes to the Program increase — or decrease — the likelihood that information will be preserved and accessible for the long-term and if changes will increase — or decrease — the social benefit that the public gets by actually using, sharing, and reusing government information. Such an approach would change the focus from one side of the equation (library managers, preservationists, GPO, “partners,” private sector companies), to both sides of the equation (including users). It should describe policies and Models that would demonstrably maximize benefits to all.

The Value Proposition should identify value accrued — or lost — to current and future users of government information including citizens in general as well as specific user communities (e.g., economists, historians, journalists, scientists, physicians, geographers, lawyers, students).

The Value Proposition should look also at the value to GPO and other government agencies of having a network of many congressionally-mandated (but non-government) libraries participating in the preservation of and providing access to and services for government information. It should consider the value of an FDLP library community to non-FDLP libraries. The existence of such a community would enrich all libraries by providing shared expertise gained through the iterative process of building collections and providing public and technical services for government information.

Rather than looking for incentives that might keep libraries nominally in the program while actually drastically reducing their commitment and participation in the Program, the Values Proposition report should describe the benefits of Program changes to users. By providing actual benefits directly to users, libraries will enhance their own relevance and sustainability. By facilitating this, GPO can attract and retain libraries that will gain benefit from sustaining or increasing their commitments rather than from lowering or dropping them.

The Blue Ribbon Task Force on Sustainable Digital Preservation and Access (Ithaka S+R’s Roger Schonfeld was a contributor to the Task Force) addressed the idea of “Value Propositions” in the digital environment. It said:

“When speaking about value, economists like to ask ‘Who benefits?’ or ‘Who cares?’ because well-articulated demand starts with a clear and compelling value proposition about the benefits to be gained by having, in our case, access to information at some point in the future. The value of information is not to be confused with its monetary or financial value per se, although it can often be denominated in currency. The value of digital assets is best understood as what digital materials are good for, and that is usually understood as the ways that the materials are used — to advance knowledge, entertain or bring pleasure, help solve problems, or inform public policy.

“Each user community will identify its own set of values and benefits in the digital materials they demand. For example, in scholarly discourse there is a clear community consensus about the value of e-journals over time.” (p. 24)

We believe that designing a Values Proposition that directly and explicitly addresses the identifiable needs of and benefits to a wide variety of user communities will be more effective than the current proposition. We believe that such an approach will benefit libraries by benefiting users and will benefit the Program by benefiting libraries.

Public comments and response to Ithaka S+R Models draft report

We have sent Ithaka S+R our comments for the draft directions and draft models documents (as well as comments on the other draft documents), but feel that a more in-depth analysis and response is warranted.

While there is much to like about this draft — as other commenters have rightfully pointed out — it has some serious gaps that could have potentially dire consequences for the future of the FDLP.

The main strength of the report is that it explicitly recognizes the need for digital preservation beyond the confines of GPO. The report says:

“Although GPO has taken on an important leadership role in preserving and maintaining the integrity of digital government information, GPO alone cannot effectively accomplish these goals; distributed responsibility for preserving and maintaining the integrity of government information is a long-standing value of the Program that must be maintained in the digital environment to provide users with confidence that the materials they use in digital form will remain available and unchanged over the long term.”

“Historically, government publications have been made tamper-resistant by the broad distribution of FDLP materials to a network of libraries, which maintain these collections independently of federal government control and can serve as an integrity check on the system. … [L]ibraries replicate this system in the digital world, ingesting and maintaining independent collections of digital FDLP materials.”

This recognition is the essential first step toward building an infrastructure of digital preservation for the long term that can withstand technological, economic, social, and political stress.

The report has several systemic weaknesses, however, that make its preliminary recommendations either inconsistent or too vague to be useful without explanations, modifications, and surveys of the community. We focus here on things we think need attention.

The Building Blocks, The Roles, The Models

To evaluate the Models presented by Ithaka S+R, one must first understand the relationship between “building blocks,” “roles,” and “models.”
The Models document presents five broad “building blocks” (sometimes called “components” or “categories”) for the program. Each of the building blocks consists of one or more “roles” for individual libraries.

The building blocks are broad categories that cover the service and collection functions of the FDLP. Together, these comprise the mission of the FDLP in aggregate.

The roles are distributed among the building blocks and are designed to give each library an opportunity to choose a role that matches its own level of commitment and participation within each building block. For example, the building block that deals with “tangible collections” has five roles ranging from having no tangible collections at all to preserving a comprehensive collection of all tangible materials.

The document also outlines some Short-Term Changes that will (a) allow Regionals to more easily become Selectives, (b) create a national needs-and-offers process, and (c) make it easier for libraries to deaccession large quantities of documents and others to collect those discarded materials.

The five building blocks and their associated roles are:

Building blocks


(1) Short-term changes (STC)

Regional role

(2) Information services

Three Service roles (S1-3) and
one Training role (Tr)

(3) Digital materials

Four Digital collecting roles (D1-4)

(4) Tangible collections

Five Tangible collecting roles (T1-5)

(5) Page-validated tangible collections

One Page-validated print collecting role (T6)

The document offers five different Models as options; each would implement zero or more of the building blocks. Participating libraries would be expected to choose one role in each building block implemented. Some of the roles require little or no formal activity; some require significant commitment and resources.


Building Block




[no change in roles]



STC, S1-3, Tr



STC, S1-3, Tr, D1-4



STC, S1-3, Tr, D1-4, T1-5



STC, S1-3, Tr, D1-4, T1-5, T6

This description of different models comprised of Program-oriented broad areas of activity (the building blocks) that are implemented through library-oriented roles is meant to create a sustainable, mission-oriented FDLP with each library fulfilling roles in each area but only at a level of participation to which the library is willing to commit.

Evaluating the Models: What would work and what would not?

It is difficult to evaluate the outcomes of implementing any of the five models because the report focuses more on descriptions of the components than it does on descriptions of the “big picture.” As written, the report makes it relatively easy for any given library to imagine choosing a particular role in any given category, but it makes it relatively difficult to imagine what the program as a whole would look like and whether or not it would be successful or sustainable.

Would the design of the models (i.e., the use of broad, program-level building blocks implemented through library-level participation in specific roles) result in a sustainable mission-oriented FDLP supported by individual libraries participating at locally-sustainable levels? Or would low levels of commitment by many libraries leave an FDLP with few active participants, heavy reliance on a few centralized institutions, and a greatly reduced number of trained staff nation-wide? The report does not address these questions.

The document does not predict the number of libraries that might choose those roles that require active, significant, formal participation. Neither does it predict the numbers of libraries that might choose those roles that require minimal or informal participation with little or no responsibility. It does, however, describe target minimums for some but not all roles (Tr, D3,D4,T3,T4,T5,T6); seven of the fourteen roles have no participation targets at all. Apparently, these minimum targets could result in an FDLP with as few as 20 or 30 active participants — perhaps even fewer.

The report writers do not tell us either what level of participation they would find ideal or what level of participation they anticipate as likely. Neither do they tell us (except for the specified target roles) what level of participation would be unacceptable. While we very much like the idea of flexibility, the draft Models report describes options without defining goals or outcomes and without tying the models to the FDLP Strategic Plan 2009 – 2014 quoted in the draft Directions document. This makes it very difficult to evaluate the potential effectiveness of the report’s recommendations.

In order to fully evaluate the proposed models, the consequences of different levels of participation should be included. Ideally, these would include the intended (ideal), anticipated (likely), and potential (worst case) consequences of different levels of participation in the different roles. These would explain both the benefits and the risks of adopting the models.

There are at least two ways the report could do this. First, it could describe how many libraries it intends to, and anticipates will, choose every role, and then describe the potential consequences of extreme cases of participation and non-participation. Second, it could describe the benefits of each role, not just to the participating library, but also to the FDLP Program, GPO, and, most importantly, to users.

Examining the Ithaka S+R vision

The requirements and options that Ithaka S+R has designed have two recurring themes. First, every model includes roles that will allow libraries to reduce or minimize their responsibilities. In some cases, this is quite explicit:

  • “…allowing libraries to take on a services role independent of collections responsibilities.”
  • “…enables libraries to take on flexible and minimal responsibilities within the Program.”
  • “…a library may take on a relatively minimal role…”
  • building digital collections that “have no formal status in securing long-term preservation or integrity.”
  • building tangible collections that “have no formal role in the long-term preservation of FDLP materials”
  • “we imagine moving into an environment in which some libraries may choose to deaccession large quantities of document[s]”
  • allowing libraries to “freely deaccession any tangible materials once they become available in digital form.”
  • empowering [Regionals] to “step down to Selective status”

Yes, we have taken the above excerpts out of context. We do so to highlight how Ithaka S+R envisions meeting the FDLP vision. The full context of the above quotes always includes the hope that allowing flexibility of participation will encourage some libraries to “stay in the program,” that minimal participation and responsibility is better than none, and that others will take on more responsibility. This could be one result of adopting one of the models, but there are other possible outcomes as well. What would happen if an inadequate number of libraries stepped up to the increased responsibilities? What would happen if a very large number of libraries decided to “step down” and take fewer or no responsibilities? We do not know from the report as written what the critical numbers are for participation.

Second, we know that the models clearly value two things: a more centralized, big-library approach to preservation of both digital and tangible materials, and a distributed, hierarchical approach to service. In the area of preservation, the report suggests relying almost exclusively on very few participants in significant roles. In the area of service, the report suggests some libraries will be able to do little, some a bit more, and some a lot. These concepts have two things in common: more libraries with fewer responsibilities and fewer libraries with more responsibilities. Will the models work because of this centralized design approach? We do not know. It is, of course, also possible that implementation of the models will result in a different result: perhaps many libraries will take on greater responsibilities and few libraries will “step down” to reduced or minimal responsibilities. But this leaves us with yet another unknown. Will the models work in spite of their centralized design?

What we do know is that the centralized/few-libraries model that Ithaka S+R suggests is a significant change from the decentralized, highly participatory traditional model of the FDLP. It deprecates the roles of most libraries and puts “more eggs in fewer baskets.”

This worries us for two reasons.

First, the more centralized Ithaka S+R approach reflects a hope that a system that consists of fewer institutions with more responsibility will be more sustainable and more effective. In our experience, larger organizations are less flexible and just as vulnerable to the problems of financial stress as smaller libraries. A larger institution may “survive” bad economic times, but at what cost to collections and services? On the other hand, a large system of diverse organizations with smaller, more specific user communities should provide a system that is more flexible (in terms of collections and services) and better able to effectively withstand economic stress than a few big institutions. What are the risks of adopting the Ithaka S+R model and substitute it for the current model? The report does not say.

Second, as noted above, the user perspective is almost completely absent from these models. The earlier Ithaka S+R reports and Findings suggest that users are satisfied with the current, largely disintermediated environment, and the current report does not explain how its models address this. It does not demonstrate that libraries or users will benefit from the hierarchical services-without-collections approach that it advocates.

We believe that many of the ideas in the Models document are good. We love the idea of a national needs-and-offers list. We are extremely happy to see the recognition of the need for multiple digital collections. We like the idea of cooperative arrangements and facilitating the building of collaborative projects. We like the idea of having new, “truly comprehensive” and “page validated “tangible” collections and big, comprehensive digital collections separate from GPO’s.

But we do not like being offered an either/or choice between traditional, distributed, user-focused collections and services, or big, centralized collections and services that minimize the roles of smaller, user-focused libraries. To us, the Models report seems to suggest a “race to the bottom.” It encourages libraries to reduce and minimize their participation and commitment and rely on a few libraries to shoulder the essential roles.
We think that a both/and approach would be better. Such an approach would build on existing strengths of a distributed system. It would encourage greater flexibility and more participation by individual libraries. And, it would offer incentives to build truly comprehensive digital AND “tangible” collections. Such an approach would benefit from the different strengths of distributed and centralized systems and would therefore be more sustainable, more effective, and provide greater benefits to users than either approach alone.

Where is Title 44?

The report does not describe how the “roles” are either consistent or inconsistent with Title 44. For example, role “T1” describes libraries that would not build or maintain any collections of tangible FDLP materials at all. The report does not say if that would require changes to Title 44.

There are several references to roles that will require GPO to select participating libraries and for those libraries to sign memoranda of understanding with GPO and to commit to fulfilling a role for a minimum period of time. Are these anticipated to be in addition to, or instead of, Title 44 commitments? Would GPO be able to select only from a pool of FDLP designated libraries, or would any library be eligible for selection?

Some of the wording in the report implies that libraries that are not current FDLP participants could take on the described roles without becoming designated as a Title 44 FDLP library; (e.g., “any library should be allowed to take on these roles with minimal formalities” and “encouraging current non-participating libraries to take on a services-only role within the Program”). Other wording specifically addresses eligibility for participation in FDLP as a prerequisite to performing a role; (i.e., “[W]ould it be possible for a 501(c)(3) digital library organization that makes freely available digital collections with no traditional, physical collections (such as the Internet Archive) to play a formal role in the FDLP?”). Are the roles described in the report open to FDLP libraries, to non-FDLP libraries, or both? What would be the impact on the outcomes of those different possibilities? Currently, we do not know the answers to these questions.

Where is the evidence?

The Models report builds on the drafts of earlier reports (Background, Environmental Scan, White Paper on Existing Library Networks, Findings, and Direction). Ithaka S+R has said that those were drafts and that final versions would be available later. Unfortunately, in our view, the “Findings” report in particular was incomplete and inadequately supported by the research described in the earlier reports. Since we have not seen a final version of the Findings or modifications of the other research reports, it is difficult to evaluate how closely the Models are justified by the earlier work. In our view, the Models document suffers from (apparently) using those earlier drafts and therefore presenting suggestions that are not supported by Ithaka S+R’s own research.

There is one particularly important example of this. One of the most important assumptions in the report is that libraries will discard print collections and rely on digitized versions of those publications. But the report does not justify digitization as an adequate replacement for discarded paper either in terms of usability or preservation. The report relies on a “slightly modified version” of the operations research model described in Ithaka S+R’s “What to Withdraw” report. It says that this model can be used for government publications, but it does not make it clear why this is a valid assumption. The “What to Withdraw” report is based on a study of digitizing scholarly journals, not government publications. Because government publications have significant differences from the scholarly journal literature, it is unclear that the “What to Withdraw” report is applicable in this instance.

Because the report’s models rely so heavily on digitization of paper, it is essential for the report to provide evidence of the effectiveness of this approach. The report does not deal with the significant differences between government documents and the scholarly journal literature. Specifically: 1) The age of documents may make scanning less accurate; 2) lack adequate bibliographic control especially for pre-1976 documents; 3) publications of odd sizes and formats may be difficult to scan at all; 4) many government documents contain statistical tables which are particularly difficult to accurately scan and convert to text, and 5) many government publications contain images, charts, photographs, and other graphics that are difficult to accurately scan. The “What to Withdraw” report itself notes that “too little is known” about digitizing images and tables and charts. The assumption that government documents can be accurately scanned overlooks (and, perhaps, underestimates) the challenges of digitization. Ithaka S+R puts the digitization cart before the deaccession horse.

We are particularly concerned about the accuracy and usability of statistical tables, which comprise a large and highly utilized segment of government publications. Until we have a verifiably reliable way of guaranteeing that numeric information can be accurately scanned, made human-legible, and OCR’d accurately, paper copies will continue to exceed the value of digitized copies for discovery, access, usability, and preservability. Such guarantees are still rare given the difficult and expensive process of digitizing such publications. OCR’d text is too often found unusable or unreliable and double/triple keying is the norm (For more on this topic, see Julie Linden’s d-lib article “Don’t leave the data in the dark” and Joseph, Lura E., “Image and Figure Quality: A Study of Elsevier’s Earth and Planetary Sciences Electronic Journal Back File Package,” Library Collections, Acquisitions, and Technical Services, 30, 162-168 [doi:10.1016/j.lcats.2006.12.002].)

If the report does not present adequate evidence for this point alone, the rest of the report’s suggestions, which are based on this assumption, become very questionable.

Where are the users?

As noted above, we believe the report would be much more valuable if it spelled out the benefits and risks of different models. In particular, we would like the final report to address how the different models and roles address the needs of and benefits to users.

While the report does deal with some big-issue general needs and implied benefits (e.g., long-term preservation), it either omits or gives little explicit attention to other needs (e.g., long-term free access and usability, discoverability, user-services). If the report addressed user benefits more explicitly, it would give a better sense of what Ithaka S+R is seeking to achieve and how likely it will be that those goals can be achieved.

The absence of a user-focus does more than make the report difficult to evaluate. It also results in omissions of important roles for the FDLP libraries and the community.

For example, the report does not consider the role of smaller collections except to assume that they have no important role in the Program. We suggest that the report should: a) Recognize that smaller, selective collections and larger, comprehensive collections are complementary, not incompatible; and b) Recognize that unique collections will, in some cases, be better able to ensure preservation and facilitate better services than comprehensive collections because the preservation activities and user services of such collections are based on the needs of specific, designated communities rather than on a generic mission to save and provide service for everything to everyone. (A “coordinated comprehensive” collection can too easily miss something that it should preserve simply because the scale of its mission makes 100% success difficult and because it has no designated community informing and verifying its activities — especially given that there is no comprehensive shelf list available to define what “comprehensive” is with any certainty). Such changes to the report would, we think, modify the roles and change the anticipated outcomes and potential consequences of the roles particularly with regard to benefits to users. This could also result in different levels of participation by libraries.

In a similar vein, the report does not suggest a role for what might be called “selective digital depositories.” By omitting this idea, roles D1-4 seem to unnecessarily limit the opportunities for digital preservation and digital service rather than create flexibility. The digital collection roles D1, D2, and D3 could embrace collaborative projects as well as projects of individual libraries. (Imagine, for example, an administrative group of libraries (for example ASERL libraries), a focus grouping such as several law libraries, a regional grouping such as border libraries, a subject or format grouping such as libraries with an interest in the environment, or GIS, or statistics, a grouping of libraries with similar users such as several undergraduate libraries or art libraries, or even children’s or school libraries, etc.)

The report also misses an opportunity to consider the needs of users and the advantages of the program to libraries when it focuses only on “local communities” and “local constituents.” By doing this, the report neglects to recognize the potential advantages of libraries providing services for non-geographically-based communities. While geographically local and nearby services are an important part of libraries’ service profile, in the digital age, libraries need no longer be limited only to geographically local constituents. By broadening their potential user-communities, libraries can at once increase and focus their user base, gain new kinds of support, and identify new sources for funding. By overlooking such opportunities, the report reduces both sustainability and effectiveness of participants.

We suggest that the report explicitly broaden the potential scope of FDLP libraries as each defines its services, collections, and constituents. Use of the terms “local” and “nearby” should be questioned and, when appropriate, changed to include services and users that are geographically nearby, or non-geographically based, or both. The report might give specific examples of how any given library might have several different communities: some geographically local, as well as some based on discipline or subject or agency content or community of interest. The examples above for digital collections would take on a broader context if considered as addressing a community of users rather than just a geographically bound community. Considering non-geographically based communities for services and even training will make the Program stronger and provide more flexibility to libraries while increasing benefits to users. Imagine a library providing services for a community of lawyers or physicians or demographers or even children. Imagine national-level training based for data and statistics, GIS, satellite imagery, API development, database preservation, and so forth.

Similarly, the report repeatedly uses the phrases “local priorities,” “program priorities” and “institutional priorities” but does not balance this focus with the priorities and needs of and benefits to the public at large. The report even suggests that libraries could make digital collections available only “for a local community” rather than “on the open web.” This turns the idea of FDLP on its head. FDLP materials, more so than any other library holdings, have importance beyond the local institution and the report should be more explicit about that. While the behaviors and choices of individual libraries are certainly affected by their own local priorities, it would be misleading to suggest to FDLP libraries that by addressing those local priorities alone they can necessarily address the wider obligation of the Program.

On one last note in this area, consider the report’s suggestion of a national needs and offers list. While we like that suggestion, we wonder why the report does not go beyond the discarding process and embrace better tools for identifying and managing collections for user discovery. The national needs-and-offers lists could be part of a larger project to build a better, more comprehensive and accurate inventory of government information. This could include digital and non-digital information and could facilitate discovery and preservation. With multiple digital collections and a role for the management of a flexible permanent link resolver, a user seeking a particular document should be able to easily get the document from any of a number of depositories without searching multiple catalogs.

In addition to facilitating tools for users and for regionals, the N&O list could be a tool for every library. As we noted in our comments on the draft models document, N&Os could be:

…more than just a shared space to upload N&O spreadsheets. It would need to be a database able to import spreadsheets and other doc formats, sortable by state/library, searchable by agency, connected to each library’s item selection (perhaps via documents data miner), have alerts so e.g. if I want to collect historically or more in-depth in a certain subject or agency, I’d get alerted whenever a new doc fitting that criteria was available. It’d also have to be able to track N&Os so we’d know to which library an offer was sent. In other words, it would need to be a tool for all libraries, not just regionals.

An alternate vision

The Ithaka S+R “Directions” document quotes the vision, mission, and values of the FDLP as described in the “Federal Depository Library Program Strategic Plan, 2009-2014” and says these are “not under reconsideration as part of this project.” Presumably, the Models report should support and further those values, or, at very least, not interfere with their accomplishment. At this point, it is difficult to evaluate the success of the report in meeting those criteria.

Given that, it is worth pausing and imaging a different set of goals — specifically driven to further the FDLP values and mission — and ask how well the report addresses those. This might give us a better “big picture” perspective on the potential outcome of adopting any of the report’s models and help identify gaps in those models.

Here is a list of some goals for a robust 21st century FDLP that we think are important:

  • Collections:
    • a large number of comprehensive analog/historic collections in various states/regions;
    • systematic and distributed preservation of analog AND born-digital documents;
    • analog AND digital “collections of excellence” (borrowed from ASERL draft proposal for managing FDLP collections);
    • broad and expanded scope of FDLP collection parameters that include databases behind dynamic web sites (not just “documents” but “data”);
    • facilitating the building of collections that go beyond the Title 44 scope of FDLP collections: collections that would include agencies and item types not traditionally collected as well as documents from local/regional offices of fed agencies.
  • Technical AND public services:
    • A documents librarian in every library;
    • public service (real and virtual) across the country;
    • Robust technical infrastructures to adequately deal with born-digital documents and open the possibility of enhanced services and collections;
    • leveraging of the Web for access, services, and information;
    • digitization AND enhanced digital access (i.e., machine readable data, georeferenced maps etc).
  • Collaboration:
    • Collaboration and communication between and among depository libraries, Federal agencies, and GPO;
    • National Needs and Offers (N&O) database;
    • Creation, maintenance and sharing of robust bibliographic metadata of collections;
    • concerted and collective effort to collect fugitives that have historically fallen through the cracks;
    • liaison program for all federal agencies as well as their local/regional offices;
    • training of new librarians in collections AND services including creation and maintenance of training materials and wiki textbooks.

The proposed Ithaka S+R models address some, but not all, of these goals. The report does not describe adequately how the goals would be met or how many libraries would be needed to meet each one. How do Ithaka S+R’s proposed models meet the stated FDLP mission, values and goals? How many of the above goals would Ithaka S+R’s models address adequately or at all? We do not know.

We believe a vision of the future that encourages more participation (rather than less) and more collections (rather than fewer) with greater diversity of focus on specific user communities would be more sustainable, more effective, and provide more benefits to more users than the current models presented by Ithaka S+R. We should be envisioning an ideal FDLP and then creating the participatory roles to meet that goal. We should be creating space for all kinds and sizes of libraries to participate in a meaningful way. The current report seems to want to save the Program by minimizing and reducing participation. Although that might have the desired effect in the short term, will it build a better, more sustainable FDLP in the long run? Will it provide the benefits that smaller user-focused collections and services can provide? Or will it result in a smaller FDLP with a few monolithic collections and service points, incapable by design of addressing the needs of any but the large aggregate of users?

Public comments on Ithaka S+R draft findings document

Attached for your reading “pleasure” are our collaborative comments on the Ithaka S+R draft findings report released on 1/14/11. Once again, we’ve done a collective stream of consciousness, inserting comments, suggestions, citations etc within the draft text of the Findings report. Please forward to those individuals, groups and listservs for which the FDLP modeling project has import. And by all means, please contact the Ithaka S+R project team at FDLP-modeling@ithaka.org as soon as possible with your own comments, ideas, suggestions etc. We’d appreciate if any comments sent to Ithaka S+R be posted here in the comments section so that the FDLP community can be informed.

Public comments on Ithaka FDLP Modeling Project draft documents (II)

[This is the second of several comments on the Ithaka S+R FDLP Modeling Project. We will tag all our comments so you can find them all here.]

What works and what does not

In this post we’ll examine what we can learn from the Ithaka S+R Environmental Scan about existing government information models that are working and those that are not working.

Two developments

The trends that emerge in the report are, for the most part, not surprising to anyone who has been following the trends in information access and libraries over the last two decades. But two developments stand out because of their huge significance to libraries and because they are developments that libraries can control. This is where our choices can make a difference to the future of libraries and the future of free access to government information.

The first development is that of disintermediation. This is the process by which users are increasingly finding that they do not need an intermediary (libraries) to identify, locate, and make use of relevant information. The report describes this development repeatedly in all types of libraries with all types of users.

The second development is the challenge of long term preservation of digital information, which the report describes in some detail in one of its longest sections (p. 24-32).

Which responses to these developments have been effective? Which work and which do not?


One of the strategies most often used and advocated by librarians to neutralize the trend in disintermediation is re-intermediation. There are two ways this has been done.

1. Force people to come to you. One way to re-intermediate is to change the environment so that people will once again have to use libraries. Although most librarians do not publicly advocate such an approach, it is the foundation underneath what libraries do when they license access to commercial services (e.g., e-journals, abstracting and indexing services, audiobooks, etc.). In these cases, libraries are benefiting from the restricted access to information imposed by publishers by making libraries a seemingly necessary intermediary. The federal government also uses this model, making some of its information available only for a fee. In some cases FDLP libraries get some sort of free but restricted access to these services, in others libraries have to subscribe to services.

GPO itself has used this model to create a new niche for itself in the digital age. At a time when printing was becoming irrelevant and a government printing office therefore unnecessary, GPO re-intermediated itself into the life cycle of government information by making it virtually impossible for the public to get whole classes of government information without going directly to GPO. It did this partly by refusing to deposit digital government information in FDLP libraries.

Effectiveness. This approach has a short-term, superficial effectiveness since it explicitly re-intermediates the library, but we already know that, in the long-term, it fails. The report describes users who access licensed services remotely but who do not appear to realize that the library is providing an intermediary service; the report implies that these users apparently believe that they no longer need the library. In addition, this strategy of negotiating and enforcing contracts that restrict access to information is not a role that requires librarians or a library. We can conclude that this approach will inevitably lead to these licensing services being provided more efficiently (and less expensively) by a business or legal office of a parent institution. We can also predict that, if we rely on this approach, it will encourage more fee-based government information services (e.g., DARTS, National Climatic Data Center Online Document Library, the Homeland Security Digital Library, Public Health Reports, USA Trade Online, etc.).

In the case of GPO, its success as a sole source of access appears to be hastening, not ending, its own disintermediation. Agencies appear even less likely to use GPO as a “publisher.” This results in more information being “fugitive” (outside of GPO and Title 44 control). And, as a sole provider of digital preservation, GPO has no Congressional guarantee of long-term funding to preserve everything forever nor to provide free access forever.

2. Provide New Services. The second way to re-intermediate is more commonly advocated publicly by librarians: It is the idea of creating new services that will attract users. The report mentions many of these “new services”: promoting “the library as a place” and as an “information commons,” providing internet access and help using the internet, providing computers and software and help using them for specific tasks such as job-hunting, and, in general, offering “higher-value services targeting the particular needs of local constituents.” In the area of government information specifically, some librarians strongly advocate libraries promoting themselves as an intermediary between the public and faceless government bureaucracies. Some suggest that government information specialists will do this, others say that all librarians will be trained in government information and there will be no more specialists.

Effectiveness. The report provides little or no evidence that these services are effective in attracting or maintaining users, nor that librarians are uniquely qualified to offer such services. In fact, the evidence in the report’s section on “Changing research behaviors and use of libraries” suggests that users are content with the information they can gather without the help of libraries or librarians. Although librarians may wish that users would ask for help and may believe that librarians could help users find better information, there is no reason to believe that users will change their behavior. This approach is little more than an unsubstantiated hope that users will turn to intermediaries at a time when all the evidence demonstrates that users prefer disintermediation.

“Local loading” and building digital collections

The other strategy described by the report is the building of local digital collections, which the report refers to as “local loading.” This is a relatively new approach since many libraries have avoided building digital collections or moved slowly to do so. The advantages of doing so are clearly stated in the report as the motivation for choosing this strategy. These include: the need by researchers for dynamic data repositories, the need for curation and digital preservation, the need by users of all kinds to link documents and data, the need of users to have information systems that are enhanced beyond what publishers and producers and distributors provide, the desire by users to have integrated selections of quality resources from different sources, the need by colleges to have enhanced course management applications, the need for better ILL and citation management tools, and the desire of libraries to offer better services and value to a library’s users.

Effectiveness. Evidence suggests that organizations that select and acquire digital content and build digital services on top of those collections are successful. Although the report mentions some of these, it neglects to mention some of the key players in this area, giving, perhaps, a diminished impression of their importance. Some of the successful projects include commercial information vendors (e.g, LexisNexis, ProQuest), non-profits (e.g., the Sunlight Foundation, OpenCongress, Govtrack), universities (e.g., the University of Virginia’s historical census browser, the Public Papers of the Presidents project at the University of Michigan and University of Wisconsin’s “Foreign Relations of the US”), consortia (e.g., CIC, LOCKSS, HathiTrust, OCUL), governments (e.g., data.gov, Thomas, FDsys), special projects (e.g., National Security Archive at George Washington University, collections at the Federation of American Scientists, OpenCRS), as well as projects in the sciences such as arXiv and the collections at the Los Alamos National Laboratory. Perhaps the biggest and most influential in this area are the Google scanning project and the HathiTrust.

All of these share the common strategy of building unique services on top of digital collections that they curate. One of the most important lessons of these projects is that their successes are based on their providing something that no one else does. This is not an artificial “re-intermediation” or a mere hope that users will recognize their need for librarians, but an actual, concrete provision of collections and services that attract users because of their actual value to users.

Benefits to users

It is worth noting that those who oppose building digital library collections often argue that the user does not recognize or care where digital information resides as long as they can access it. This argument misses two essential characteristics of local collections, however.

First, users will see the advantage to using the local digital library collection when the library does something with the content that the remote provider does not (and often cannot) do. Libraries with their own digital collections can provide search and discovery tools that integrate information from many sources; they can provide computational analysis and data mining tools; and they can provide APIs that reflect their users needs for using and repurposing information. Perhaps most importantly, they can combine information from many sources to build unique collections that reflect the interests and needs of their designated user communities. This will make it easier for their users to find what they need without having to sift through irrelevant material on the open web and without having to visit multiple, isolated, proprietary, deep-web/hidden-web sites.

Second, users will derive the benefit of locally maintained collections when libraries keep something online that would have otherwise disappeared. This is where libraries can address the second major trend we identified above: digital preservation. The Ithaka S+R report, unfortunately, confuses this issue by bringing up the old cliche of “access vs. ownership.” This hackneyed adage is, today, out of date and misleading. It a false dichotomy because we cannot ensure access unless we have control over the content. Simple “access” to information over which we have no control is at the mercy of those who control the information. In addition, preservation and access are inseparable in the digital world and preservation is inseparable from “ownership,” i.e., control. When something is removed from the web (or altered), whether it is accidental or intentional, whether it is done for economic or political reasons, whether it is the “right” decision for one organization or not, the result is the same: the user can no longer access the information he or she needs.

Libraries can prevent information from disappearing and can ensure its long-term preservation. Even smaller libraries that do not see themselves as having long-term preservation as a primary mission will realize that their size often means that their community has information needs that are overlooked by large, monolithic preservation projects. Cooperation and coordination of many small, medium, and large collections will help ensure that information needed by even a small group of information users will not fall through the preservation cracks.

While surveys may not reveal that users understand this as a need today, users will appreciate and understand it in the long run. In the short term, it is librarians who must act now with this long-term vision in mind. Later will be too late. If we fail today, users of tomorrow will recognize our failure and not see a reason to support institutions that did not look after the interests of their communities.


As the Ithaka Findings document notes, “GPO cannot on its own serve as the single trusted party to ensure the preservation and integrity of the digital and digitized FDLP collections.” The only question that leaves us with is, Who will work with GPO to preserve and ensure free access for the long-term?

Attempting to make libraries relevant to users in an era of disintermediation by attempting to artificially re-intermediate libraries will fail. Building local digital collections will make libraries relevant to users (in ways that no one else can match) and accomplish digital preservation (which no one else can accomplish alone).

Comments on FDLP Modeling Project draft documents

[This is the first of several comments on the Ithaka S+R FDLP Modeling Project. We will tag all our comments so you can find them all here.]

Introductory comment

Status of the drafts

Our comments will address the first three documents from the FDLP Modeling Project.

Roger C. Schonfeld, Manager of Research at Ithaka S+R, wrote to us to clarify the status of these documents. Though some are labeled as “final drafts” They are actually the “final draft[s] of the public draft[s] — but not the final draft of the section [of the final report].” He noted that “…all three of the deliverables that we’ve released publicly to the project website are very much drafts for community input and review, which input will be incorporated in further stages of the project and will lead to the appropriate revision of these sections prior to the issuance of our final report.”

A bit of background: Our perspective

We at FGI come to these issues as unpaid volunteers who advocate “Free Government Information” — free as in no-fee and free as in free from constraints and controls on re-use. Our comments are informed by our daily work in both the physical and digital realms of government information.

We are committed to a digital future for government information. We come to this process with, collectively, decades of library work experience with digital projects as well as decades of experience providing services for government information at all levels of government. We have always looked for solutions that work for information users and will continue to do so.

How should we evaluate the current environment and plan for the future?

While it is useful to understand the context within which libraries operate, we should not mistake that context for a vision.

To plan a future that provides for free, permanent access to government information we must do more than examine cost-constraints and current trends. While library finances will certainly limit what we can do, they should not warp our vision of what we should do. We should decide what we want first; then we can develop realistic ways of achieving our goals. While current trends in information technology, government agency policy, and commercial information practices provide the context within which libraries operate, those activities reflect the visions of others and we should not let those trends dictate our vision of the future.

It is also important that we do more than examine current user-behavior. We shouldn’t blindly follow users; instead, we should use current user-behavior as an indicator of what users want in the future. Users may be happy that they can access government information today but we have a responsibility to go further and ask: “What will guarantee that access tomorrow?”

While technology changes, our fundamental values are constant. Technology does not limit our choices, it broadens them. The challenge is not that we need to amend our values (e.g., access, privacy, long-term preservation, reuse) in light of technological changes. The challenge is how to use technology to assure access, privacy, long-term preservation, and reuse. Libraries are well positioned as public, non-commercial stakeholders to lead this process.

We believe that libraries should embrace a vision of the future that goes beyond what any single institution (e.g., GPO, individual agencies, individual FDLP libraries) could accomplish on its own. Reliance on any single institution is much riskier than relying on many — particularly in times of deep financial uncertainty. No single institution can guarantee that it can do everything for everyone forever. Relying on many institutions spreads the burden and the risk. Relying on many institutions provides opportunities for broader, more diverse services and collections.

Finally, we believe that the future of FDLP is about control. Who will control the information? Will it be government agencies (including GPO)? Will it be private sector vendors? Or will it be a large community of libraries working for the benefit of their various communities and constituents, preserving both the digital information and the communities’ right to free access to that information?

It is with these ideas and values in mind that we will examine the information that Ithaka S+R has compiled. We will attempt to draw conclusions from that information that will lead us to a future of free, open, usable, well-preserved government information where citizens, not governments or corporations, control their information.