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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.

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.

Public comments on Ithaka S+R FDLP Modeling draft documents

Starting today and continuing for the next few days, we will be posting comments here on the first three documents from the Ithaka S+R FDLP Modeling Project.

Ithaka S+R is now moving forward to the analysis phase of the contract. We thank Ithaka S+R for their work so far and hope that our readers will make the time to read through the drafts and also give their comments to the Ithaka S+R team.

The three Ithaka S+R documents are largely descriptive rather than evaluative and will inform the recommendations from Ithaka S+R, which will come later. In our comments on these documents we will draw some conclusions and attempt to find meaning in the overview that Ithaka S+R has provided. Our comments will be informed by our daily work in both the physical and digital realms of government information.

We will address questions such as:

  • What approaches to government information in the digital age are succeeding and what approaches are failing?
  • How can libraries lead and create their own future?
  • What can we learn from users?
  • What can we learn from the history of the FDLP that applies to our current environment?
  • Will the FDLP help or hinder libraries?

For those that are interested (or masochistic :-)), attached and linked here is a PDF of our notes in stream of consciousness on the current drafts. We used Pirate Pad to collaboratively take notes and discuss issues. We’ve sent these to the Ithaka S+R project team — but don’t say we didn’t warn you ;-).

Wikileaks, FDLP modeling and other random links of interest

It’s been a busy couple of weeks here. I’ve got a bunch of tabs open that I’ve been meaning to read/watch. And the end of the year is about lists anyway, so here’s a list of randomly interesting things to read and watch. And by all means, read and comment on the recently released draft documents at FDLPmodeling!!

Wikileaks related links:

Other links of interest:

Ithaka process examining FDLP

Ross Housewright has a post on the fdlpmodeling blog that explains in a bit more detail how Ithaka S+R will proceed in its contract with GPO to “develop sustainable models for the FDLP in the 21st century.”

There is good information in the post, and I urge you to read it closely.

The GPO RFQ requires Ithaka S+R, to develop a value proposition for the “21st century Federal Depository Library Program.”

“Value proposition” isn’t defined in the RFQ, so we are left to wonder exactly what GPO expects. Value Proposition is a term from business and management and has a variety of inconsistent meanings. As a practical matter, value propositions may be very vague or quite precise.

In response to Ross’s post on the project structure and process, I posted the following comment to the fdlpmodeling web site:

Thanks for this outline of your work plan. Your description of how you are interpreting GPO’s requirement to produce a “Value Proposition” raises some more questions. You say that you will analyze “how the roles and incentives associated with the overall recommended direction, as well as the individual model or models, match with library needs” and how your recommendations would help in the “articulation of the benefits associated with participation.”

To me, these definitions sound like you will limit the “value proposition” to benefits to libraries and, more specifically, to libraries that “participate” in FDLP (by which, I presume you mean FDLP libraries).

Do you intend to leave out of your value proposition benefits to information users and the communities (not necessarily geographically-based in the digital age) that FDLP libraries serve?

I would hope that in identifying the “value” of any recommendations you make, you would take the time to identify value accrued (or lost) to current and future users of government information including citizens in general as well as economists, historians, journalists, political scientists, physicians, geographers, lawyers, students, and others (just to name a few who we know rely on government information).

I would hope that you would look at the value to GPO and other government agencies of having a network of congressionally-mandated (but non-government) libraries participating in the preservation of government information. I would also hope that you would consider the value to non-FDLP libraries of having, as part of the larger library community, a community of libraries that specialize in government information.

In an earlier comment (http://fdlpmodeling.net/?p=1#comment-81597121), I asked if you will be using a traditional commercial/marketing approach to developing a value proposition and how you anticipate specifying or quantifying a value and costs. Have you made decisions about this? To repeat my earlier questions: Will you include costs assumed by FDLP libraries and government information users or only costs assumed by GPO? How will you quantify the value and benefits of permanent, free public access to all government information (including non-current information such as old censuses and old annual reports)? Will you also consider what risks your recommendations create for the loss of free access to government information and the costs associated with any such losses?

Finally, I believe that Ithaka S+R’s Roger Schonfeld was a contributor to the Blue Ribbon Task Force on Sustainable Digital Preservation and Access. Will your current work use a similar understanding when your develop a value proposition?

Here is the BRTF definition (page 24 of http://brtf.sdsc.edu/biblio/BRTF_Final_Report.pdf):

“2.1.1 Value and Benefits”

“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.”

Thanks for your time in considering these issues.

Who Do You Serve and What Do You Do?: Defining Your Role to Ensure the Future of Our FDLP

The Defining Moment
As noted here recently, the depository community is into yet another round of trying to redefine the Federal Depository Library Program. (See: GPO contracts Ithaka S+R to develop sustainable FDLP models.)

This new project will question and evaluate the role that FDLP libraries will play in the lifecycle of government information. The definition of this role will determine whether or not FDLP libraries will deserve or get support from their constituencies. If they serve a useful function, they will get support; if they do not, they will not.

This is a defining moment. Libraries will not flourish or even survive because librarians like them, or because older people have fond memories of them, or even because we have a vague belief that they “should” survive. They will survive only if they fulfill a role in society that no one else fulfills as well — or at all — and if society recognizes and values that role.

Make no mistake about it: what is at stake is the survival of FDLP libraries. By defining the role of FDLP libraries, this project will determine whether or not there will be Federal Depository Libraries at all.

Defining the role of libraries
Typically, the roles of libraries are defined either in general terms of who the library serves or by enumerating specific tasks. You could call these the “who you serve” approach and the “what you do” approach. Each has advantages because each one can help focus our thinking and give us criteria against which we can evaluate our actions.

Since 1993, GPO has effectively defined a limited — and shrinking — role for FDLP libraries. The FDLP has always been a cooperative venture in which different partners (GPO, regional depositories, selective depositories) played different roles. But, since 1993, when The Government Printing Office Electronic Information Access Enhancement Act (Public Law 103-40) was passed, GPO has arrogated to itself the role of permanent preservation of government information and essentially prevented FDLP libraries from undertaking that role by refusing to deposit digital materials with depository libraries.

But that is changing. Recent developments (for example, GPO collaborating with LOCKSS in the LOCKSS-USDOCS project) have demonstrated that GPO is open to sharing responsibility, is no longer committed to preventing libraries from participating in digital preservation, is open to “digital deposit,” and is, in general, open to new roles for FDLP libraries. These “new” roles could look a lot more like the traditional roles of FDLP libraries. Yes, we need to change the FDLP for the digital age, but these should not be changes in our traditional roles (what we do: build collections and provide services for and stewardship of those collections) but changes in procedures (how we do these things using digital tools instead of paper tools). It is in those traditional roles that libraries have a unique value in society. The Ithaka/GPO project will define the role of FDLP libraries either in a way that will expand this new openness, allowing libraries to have the flexibility to participate actively, or in a limited and passive way in the mode of the 1993-2009 model.

1. Who do you serve?
In defining the general role of libraries (who a library serves), there is a popular tendency to focus on the parent institution. This is an easy role to justify and explain and it even lends itself to some degree of quantification and accountability. The recent report from the Association of College and Research Libraries, The value of academic libraries: A Comprehensive Research Review and Report (by Megan Oakleaf, 2010) is a prime example of this view.

An alternative view is that libraries fulfill a larger role in society as a whole and thus serve more than their parent institution. The Darien Statements on the Library and Librarians (by John Blyberg, Kathryn Greenhill, and Cindi Trainor, 2009) is one recent example of this broader view of the role of libraries in society. Barbara Fister, a librarian at Gustavus Adolphus College, has written eloquently about this. New initiatives such as the NSF’s rules for sharing of data and creating explicit plans for managing data for the long-term are driving libraries to anticipate a larger role for libraries in fulfilling the societal need for long-term stewardship and curation of information of all kinds across the life-cycle of information. We can anticipate this as a coming major shift in focus and priorities from the local to the global role of libraries.

While these two different views need not exclude each other, in practice they sometimes do. It would be wiser to view these two ideas as complementary rather than incompatible. I would argue, in fact, that any definition of the role of libraries that excludes one or the other of these views will almost certainly be incomplete and fatally flawed.

The role of FDLP as a whole vs. the role of individual FDLP libraries
I would expect that most people in the depository community would assume that the role of FDLP must, by its very nature and purpose, reflect a society-as-a-whole mission and go beyond the missions of individual participants in the program. It will be hard for Ithaka S+R to suggest a model that avoids the big, societal role of the FDLP. But the details of how to fulfill that societal role is the issue. What specific tasks will Ithaka S+R define for depository libraries, on the one hand, and GPO and other (unspecified) “partners” (RFQ, page 5), on the other hand? These definitions will either open up the options for libraries or explicitly limit them.

Despite broad statements of the role of the FDLP as a whole, such as “create an informed citizenry and an improved quality of life” (RFQ, page 4), I think we may see considerable pressure to use a narrow definition of the role of the individual depository libraries. One reason for this is the recent history of GPO and the FDLP in which GPO took over complete control of long-term preservation and access to all digital information in the program and relegated libraries to a role of only providing customer service. Some will see this split of roles as a de facto standard that should be continued. I would argue that, while that split may have seemed appropriate 17 years ago, much has changed and libraries are now more tech-savvy and better equipped to take on digital challenges. Those who argue for the 1993 status quo are the true luddites. It is a time for change.

The pressure to limit the role of libraries will come, I think, from librarians who view the role of their own library as limited to fulfilling the mission of their own institution — those who would like someone else to take on the big, societal mission. It will come from those who support the Oakleaf ACRL report and its institution-focus and emphasis on “return-on-investment, commodity production, [and] impact.” It will come from library directors who, for legitimate but parochial reasons, want to weed depository materials from their collections and do not wish to invest in digital depository collections. It may come from Ithaka S+R itself whose Manager of Research, Roger Schonfeld, has already praised the ACRL report because it “clearly frames the purpose and value of the academic library in the context of the parent organization.” And, it may even come from some at GPO, since it matches the model GPO developed in 1993.

But there are those who will be advocating a broader, more active role for FDLP libraries. Those of us who believe that a network of Congressionally-mandated libraries can provide a better, more secure, more robust, more flexible, more responsive system than GPO or GPO and a few commercial “partners” could provide by themselves. One way to do this is to focus on the specific tasks that those libraries might undertake.

2. What do you do? The specific tasks.
There are a number of options for the tasks and roles of libraries. Many of these have been been well articulated and tried with varying degrees of success. For example:

  • Libraries as “service centers.” You might call this the “libraries without collections” or the “librarians without libraries” model. This is the model designed by GPO in 1993. It is the model that ITHAKA, the parent organization of Ithaka S+R, has used as its own business model for Portico and JSTOR. This model is favored by the Association of Research Libraries, by many library administrators who apparently believe that it would be better if someone else took the responsibility of preserving government information and ensuring its long-term accessibility and usability, and by many depository librarians who do not have the support of their institutions to build and manage digital collections.
  • Libraries as “business centers.” This model is an extension or complement to the above model because it, too, envisions libraries without collections. It sees the library as the agent that manages leases and licensing agreements with publishers and other producers (including government agencies). This model is advocated by ITHAKA, by commercial data providers who make a profit by limiting access to information to those who pay for it, by government agencies that have accepted that they must be self-supporting and thus sell their information, and by the information industry, which would like the role of libraries to be enforcers of rights-management. In addition, most libraries have already accepted this model for many classes of digital information by leasing access to databases or electronic journals instead of demanding their own digital copies.
  • Libraries that provide both collections and services. This is the traditional library model in the paper world and it is increasingly the new model in the digital world. Examples of libraries doing this include libraries and projects of all shapes and sizes: The California Digital Library, the Hathi Trust, the Scholars Portal of the Ontario Council of University Libraries, the Legal Information Archive of the Chesapeake Project, the North Carolina Digital Repository, the Stanford University Freedom of Information and CRS and FRUS collections at Archive-It, the University of North Texas digital government collections, the LOCKSS-USDOCS Network, the Historical Publications of the United States Commission on Civil Rights at the Thurgood Marshall Law Library at the University of Maryland, the many U.S. Government Publication Digitization Projects, and many more. This is also the model that private sector government information service providers use when they obtain copies of digital information so that they can provide services for that information rather than trying to provide services for collections that they do not hold. This model also fits the OAIS preservation model which requires that an archive “obtain sufficient control” of information in order ensure long-term preservation.

Defining our own future
Over the past two decades GPO has redefined the role that FDLP libraries play in the lifecycle of government information by reducing that role to one of providing service for collections held by GPO and others. FDLP Libraries have largely accepted this de facto redefinition of their role. Why? Because they have been caught in a perfect storm of inadequate budgets and staffing and training, demands from library administrators to reduce the size and footprint of paper collections, users who were quick to accept online access without demanding — or even being cognizant of — long-term preservation, and a GPO that promised it would single-handedly take on the pesky problem of managing and preserving a single digital collection for everyone while simultaneously providing “access.”

That model is failing and GPO is now open to a new model that involves depository libraries as active participants again. We have an opportunity with the Ithaka/GPO project to take the lead in defining the future of our own libraries. In the last two decades, depository libraries have followed the lead of GPO and accepted a diminished role of providing services without collections. We have followed the lead of technologists and digital-pundits who like to call the Google Books project a “library” while simultaneously diminishing the importance of actual libraries that are accountable to their communities. In a chicken-and-egg situation, our diminished activities have made depository activities easy targets for budget cuts that further diminished our ability to provide adequate digital services. As the private sector steps into this gap, our services begin to pale in comparison. We have not adequately differentiated ourselves from the private sector and government digital services, preferring to piggy back on what they do, enforce their rights-restrictions and their privacy-encroaching policies. But that strategy has endangered the principles of the FDLP and reduced our ability to do what the private sector will not and the government cannot do alone. Now we have an opportunity to change all that.

Where GPO must have a one-size-fits all collection and service model, FDLP libraries can each focus on their own communities of interest. Where private sector companies limit access to those who pay and GPO is specifically authorized in the 1993 law to “charge reasonable fees,” FDLP libraries are dedicated to providing information without charging. While the private sector, by definition, provides only those services that generate a profit, FDLP libraries are funded to provide services for their communities by leveraging the resources of the community for the benefit of all. A GPO-centered model of preservation is fragile because it has only a single budgetary authority and a single, monolithic “community.” In contrast, a preservation model based on FDLP libraries has as many as 1000 budgets, 1000 communities, 1000 locations, 1000 systems, and 1000 reasons to survive and flourish. It is 1000 times more secure.

FDLP libraries can build new digital collections that combine Title-44-materials with non-Title-44 materials. GPO cannot do that. We can support our own communities-of-interest that need no longer be geographically based. GPO has to serve everyone and does not have the resources to focus on every potential community of interest. We can build services and functionalities for our collections that focus on our communities of interest. GPO must provide generic services and generic APIs. We can guarantee that we will preserve the information in our collections for as long as those materials are of interest to our communities. GPO cannot guarantee that Congress will continue to fund preservation for everything forever. In fact, the RFQ does not contain the words “preservation” or “long-term.” We can assure our communities that we will preserve their privacy and provide information that is usable and without fees. GPO cannot make those guarantees. We can, collectively, do a better, more secure job of preserving government information for the long-term and assuring that it will be available and usable without fees than any single institution or agency can. Together, we can build a twenty-first century FDLP that will do for digital materials what the FDLP has always done: ensure long-term, free, public access to government information.

It should be clear to us that returning to a model in which FDLP libraries take an active role in building and preserving collections and providing services will provide clear benefits to users of government information. But the benefits go beyond providing access and services. A strong FDLP also benefits the participating libraries, and other non-participating libraries. GPO and the Depository Library Council are working to create a comprehensive list of benefits for libraries participating in the FDLP and benefits afforded to the public by having access to these libraries.

Start today!
While the Ithaka/GPO project provides an opportunity to turn the FDLP around and make it viable and useful in the twenty-first century, it is not at all certain that this will happen. As noted above, there are those who will argue for the status quo that limits the role of FDLP libraries to an unsustainable, unjustifiable service-without-collections model.

Ithaka S+R has already written a report with a model for the FDLP (Documents for a Digital Democracy: A Model for the Federal Depository Library Program in the 21st Century). In that report, it recommended that “GPO should develop formal partnerships with a small number of dedicated preservation entities — such as organizations like HathiTrust or Portico or individual libraries — to preserve a copy of its materials” (page 44, emphasis added). As noted above, Ithaka S+R is affiliated with Portico through their parent organization, ITHAKA. (For another take on a related Ithaka S+R study, see: Nyquist, Corinne(2010) ‘An Academic Librarian’s Response to the “ITHAKA Faculty Survey 2009: Key Strategic Insights for Libraries, Publishers, and Societies”‘, Journal of Interlibrary Loan, Document Delivery & Electronic Reserve, 20: 4, 275 — 280.) Although Roger Schonfeld has assured us that this time Ithaka S+R recommendations “will not focus on specific brands, services, or products, including those provided by any part of our organization,” it appears that we will have to convince him and Ithaka S+R that FDLP libraries, not just a “small number of dedicated preservation entities” like Portico, must play a significant role in the preservation of FDLP library materials.

Ithaka S+R has pledged that their work will include broad, vigorous community engagement and that their work will will rely on community input and advice to guide their research and define their recommendations. It is time for us to speak up. Here are some things you can do today:

  • Participate in the discussion on the project web site.
  • Participate in FDLP’s work to create a comprehensive list of benefits for libraries participating in the FDLP.
  • Work with your colleagues to create a list of benefits to your own library of being an FDLP library. Share this with your library management.
  • Identify your own library’s user-communities. Do you have subject collections that are used by people beyond your local geographic community? Would those collections be enhanced if they included government-produced information? Make the case to your communities and your library management.
  • Do you already have digital collections? Do you have digital collection tools that you could apply to government information? Or would you like to develop digital collections and services with copyright-free, DRM-free digital materials? Develop a plan that will enhance your library’s digital future by utilizing free government information content.
  • Add your comments and ideas here to this post on FGI.

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