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 missing piece: Digital Collections
• A different kind of 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. Continue reading →

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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." Continue reading →

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