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DLC responds to open letter regarding the new Regional discard policy
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.
Open Letter to GPO regarding the Regional Discard Policy
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.
Sincerely,
Bernadine Abbott Hoduski
Susanne Caro
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
Shari Laster
Lawrence R. (Larry) Meyer
Aimee Quinn
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
Information sharing and the National Plan
(Background here: http://freegovinfo.info/node/10285)
At the 2015 Depository Library Council meeting on October 20th, Mary Alice Baish, Superintendent of Documents, informed the depository library community that in July, GPO had formally requested permission from the Joint Committee on Printing (JCP) to allow Regionals to discard documents in tangible formats that have been retained for seven years when an authenticated, digitally signed version is available on FDsys. The response GPO received in early August approved this request, setting the additional condition that a minimum of four physical copies of each document be maintained within the FDLP, and suggesting the use of existing Census regions to ensure the geographic dispersal of these copies.
According to GPO’s presentation, the process for approving the withdrawal of tangible items at Regionals and identifying the geographically dispersed copies retained in tangible format will be conducted for the time being based on GPO’s ten existing print procurement regions. Six libraries have been identified to pilot the process, and GPO staff will work with these institutions to begin withdrawing materials in January 2016.
The presentation was webcast live and is available as a recording; the Regionals meeting later in the evening was also webcast live and is also available. Following the conference, GPO released the letter from GPO Director Davita Vance-Cooks, and the reply from Congressman Gregg Harper, Chairman of the Joint Committee on Printing. No final version of the policy has been made available at this time.
It is clear that GPO has listened to the community to some extent: the presentation identifies specific GPO activities that address community concerns including seeking trusted repository certification for FDsys and prioritizing bibliographic control projects for the national collection. Still, the available documentation suggests that there has been very little information shared between GPO’s request for feedback and discussion in April 2014 and the announcement of the policy’s implementation in October 2015, other than a request for information regarding intent to discard from Regionals.
Setting aside the wisdom of identifying a minimum number of tangible copies, let alone such a low number, and also setting aside the question of how preservation and access copies will be identified and maintained, this project represents a pattern in how FDLP initiatives are discussed and documented.
At the same DLC meeting, the FIPNet update was a lively discussion of various collaborative projects undertaken by individual libraries and library consortia. The second part of the program featured a presentation from Dr. Katherine Skinner, Executive Director of the Educopia Institute, on the value of collective action, which is a key element motivating any project that must be carried out on a widely distributed basis. Both recordings are linked below.
While the variety of approaches to preserving government information is laudable, only the University of North Texas has signed a formal FIPNet partnership agreement. To the best of my knowledge, no other organization has formally announced its intent to join FIPNet yet. Anecdotally, it seems that at least some potential partners are waiting to see what a partnership would entail, prior to committing. There are two opposing forces at play: on the one hand, GPO has stated its intention to be flexible and open to partnership opportunities, which precludes providing structured articulations of what FIPNet participation entails. But the lack of documentation and specifics makes it more difficult for potential partners to identify the roles or responsibilities they wish to take. While I hope there are a substantial number of closed-door discussions between GPO and potential partners, we have no way to know.
Both FIPNet and the implementation of the Regionals discard policy are part of the National Plan. But the Plan itself is not a plan: instead, it is a strategy outlined in presentations, with a few key diagrams available in handouts and slides posted on the website. In my experience, community members are still asking each other “Where is the National Plan? What is FIPNet? Is it here yet?”
We’re all in uncharted waters here, but the community outside of the Depository Library Council (DLC) is at a particular disadvantage. It’s understandable that GPO leadership would be cautious in formal public commitment to specifics for programs that are under development, especially a program like FIPNet, which has few existing precedents. However, when the only detailed documentation for a project or initiative are recorded conference sessions, it is hard to both believe and persuade others that this is a fixed course of action for GPO.
It is vital for the depository library community to understand projects and initiatives to communicate about them with library administrations and those working outside of government documents. Still, many (and perhaps most) depository librarians are simply not sure how to explain the National Plan or FIPNet. Without a formal guiding document, anyone trying to understand these developments must wade through a maze of recorded presentations and handouts. Even clearly-labeled draft or discussion documents would be an improvement in access to this information.
I have an enormous amount of respect for all of the work that Library Services & Content Management (LSCM) does on behalf of the FDLP: this office has some of the hardest-working, most dedicated librarians I’ve had the fortune to meet, and asking for more documentation means more time spent writing, editing, approving, and publishing documents that will become outdated as the systems develop and progress. Still, it is the documentary trail that we need to rely on for our shared understanding of where the FDLP is, and where it is going. Otherwise, we are doing the best we can by word of mouth alone — and that may not be enough.
Selected Bibliography
Martin Halbert et al. “FIPNet and Stratigies for Utilizing the Collective Impact Model.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated 19 October 2015.
Federal Depository Library Program. “Regional Meeting.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 20, 2015.
Library Services & Content Management. “Implementing the National Plan: Focusing on Users and Services.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 19, 2015.
Library Services & Content Management. “New Regional Depository Library Discard Policy.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 20, 2015.
Library Services & Content Management. “JCP Approves Regional Discard Policy.” http://www.fdlp.gov/news-and-events/2403-jcp-approves-regional-discard-policy. Updated October 22, 2015.
Katherine Skinner. “From Collaborative Action to Collective Impact.” http://login.icohere.com/public/topics.cfm?cseq=1328. Updated October 19, 2015.
One year later…what’s happening with Regionals and discards?
In April 2014, GPO presented a draft policy (also known as an “SOD” or “Superintendent of Documents Public Policy Statement”) that would create a mechanism for Regional depository libraries to request permission to substitute specified tangible holdings for authenticated electronic holdings in FDsys. FGI has already responded in detail to this proposal (see “Why GPO’s proposed policy to allow Regionals to discard is a bad idea”).
Library associations and organizations also published letters in response to the proposed policy. As FGI has documented (see “Library associations weigh in on GPO’s proposed policy to allow Regionals to discard”), both those supporting and opposing this policy outlined steps that GPO should take so that the FDLP can continue to meet its obligations for permanent access to the national collection of U.S. government information. Given that many of these projects will be the focus of updates at the upcoming 2015 DLC Meeting and FDL Conference, I want to summarize what information we have so far on GPO’s activities as they relate to some of these recommendations and suggestions.
GODORT Recommendations
In its letter dated August 18, 2014, GODORT requested that GPO take four major steps prior to the adoption of any policy allowing Regionals to substitute electronic versions of authenticated publications hosted on FDsys.
- GPO and the FDLP community should jointly develop a national inventory of historical federal publications held in depository libraries.
- GPO and the FDLP community should use a research-based approach to making decisions regarding the appropriate number of tangible copies of a publication needed for access, re-use, preservation, and re-digitization.
- FDsys should undergo the Trusted Repository Audit and Certification (TRAC) audit process.
- GPO should adopt a quality assurance (QA) process for digitized and born-digital publications made available for substitution.
(Full disclosure: along with James R. Jacobs, I was a member of the group that drafted GODORT’s response letter, and I was also a member of the Steering Committee that voted on the final letter.)
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