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GPO’s new Regional Discard Policy and GPO’s recent presentations about it are full of hopeful words and good intentions. We applaud GPO for having good intentions and high hopes, but we question if the Policy can meet those expectations.
- Introduction of the Policy and its Implementation
- One definite Goal. Some questionable objectives
- Preservation of and Access to Paper Copies
- Next steps
Here is what you need to know about the Discard Policy. GPO’s caveats and assurances about the new policy aside, there will no longer be any Regional Depositories for documents more than seven years old. It removes the requirement that there be access paper copies of all documents in the FDLP. It weakens the FDL Program by continuing the shift of responsibility away from FDLP members and toward GPO. It does not increase flexibility (as advocates of the policy claim), it shifts flexibility away from Selectives and gives it to Regionals. It puts new burdens on Selective Depositories. It establishes a new model for the preservation of paper copies of documents that is undocumented, unproven, and risky. It ignores long-term implications in favor of short-term benefits to a few large libraries. It makes GPO’s “guarantee” of long-term, free access to government information nothing more than a hollow promise.
We believe that the Policy actually weakens the FDLP and damages both access and preservation. We believe that the Policy provides no guarantee of meeting those expectations, and will make it more difficult to do so. Below, we explain why.
At the Fall Depository Library Council (DLC) meeting, GPO gave a general outline of how it will proceed to allow Regional Depository Libraries to start discarding paper copy documents.1 GPO has, so far, provided the following information about the Policy itself and how GPO intends to implement the policy:
- Government Publications Authorized for Discard by Regional Depository Libraries [draft policy, 07/09/2014]
- Vance-Cooks, Davita. [letter (July 10, 2015) from GPO to Gregg Harper, Chairman Joint Committee on Printing (JCP) requesting approval of policy to give regional Federal depository libraries the option to withdraw tangible depository materials]. and Harper, Gregg. [letter (August 5, 2015) to GPO] Both documents in one PDF file here.
- Council Session on Discards audio recording and presentation slides (10/20/2015)
For additional background, links, and commentary, see: Information sharing and the National Plan by Shari Laster.
The new policy has only one stated goal: To allow regional depository libraries the option to discard paper copies of government documents.2. To be clear, this is not a substitution of one format for another, like microfiche for paper. Regionals will not be required to uphold their Title 44 obligations to “retain at least one copy of all Government publications either in printed or microfacsimile form.” (44 U.S.C. §1912).
In addition to this specific goal, GPO has expressed a variety of objectives, which it apparently hopes the new policy will help accomplish. But GPO has been both inconsistent and vague in its expression of these objectives and how it will actually implement the policy.3 Six Regional Depositories will participate in a test of the policy in early 2016; presumably, this will produce more implementation details.
Some of GPO’s objectives (such as giving Regionals “the ability to expand their capability to serve the increasing number of remote users” [Vance-Cooks]) can be accomplished without the new policy.
Most of the objectives relate to giving Regionals the “flexibility” to discard paper copies of documents. GPO does not claim that this will have any positive effect for users. On the contrary, GPO acknowledges that regionals that are already relocating tangible collections to offsite storage are impairing the goals of the FDLP.4 GPO implies that Regionals will use resources that will be freed by discarding documents “to focus on the needs” of users of government information [Vance-Cooks]. But GPO does not specify what the resources are, or explain how it expects freed space to be reallocated to services or collections for users of government information, or require any such reallocation. Furthermore, some Regionals have admitted that any savings brought on by this policy will not go toward public service of government information, but will go toward their library’s central operating budget. Since the Policy does nothing to further such objectives, we should not read them as objectives of the Policy but as wishes of GPO.
Never Trust A Corporation to Do a Librarian’s Job (via lifeguardlibrarian.tumblr.com)
“We were having our own doubts, of course. How could you not? The Google Books project seemed to be letting itself go. Things any librarian would notice: bad scans; faulty metadata; narrowing the scope of public domain; having machines do jobs that should be done (or at least overseen) by humans. They seemed to be restricting and worsening access to cultural content, not expanding and improving it. Maybe we were going in different directions?” [full article]
I too have come across an increasing number of messy and illegible Google Books. Indeed, Google is a corporation, not an archivist, and we can’t rely on them to create preservation-worthy documents–especially Gov Docs. Don’t get me wrong–I have met really awesome and accomplished people who work on the Google Books project, but at the end of the day, Google[‘s] Books privilege/s commodity over content. Considering Gov Docs are instrumental to our Democracy, we need folks who will ensure scans are absolutely perfect. (On that note: GPO is embarking on a much-needed preservation project [announcement is the gov-info.tumblr queue]; I urge archivists to get get involved.)
However-as we know, digital files are much more fleeting & fragile than paper, so they should never, ever replace hard copy.
Here’s a short piece from a recent CBS news broadcast about preserving the CD collection at the Library of Congress. It was so sad to see the example CD they showed was from the Census Bureau US Exports of Merchandise.
An interesting perspective on the limitations a simple web search comes today from an Emeritus Professor of Criminal Justice at the University of Nebraska at Omaha. He notes that “The contested history of Executive Order 11246 is an important aspect of the history of the modern women’s rights movement and of the presidency of Lyndon Johnson,” but that a simple search for it yields the revised, not the original, version of the order:
- The Perils of Internet Research: The Case of LBJ and Affirmative Action, By Samuel Walker, History News Network (5-28-12).
A standard Google search for “Executive Order 11246” yields multiple web sites, including those of the U.S. Department of Labor (which enforces the federal contractor provision), the National Archives, and Wikipedia. These sites post the current revised version of E. O. 11246. While it duly notes the many revisions over the years, only historians who are specialists on the subject and some employment law attorneys (but only those interested in history), will realize that it is not the original. Consequently, they will gain no hint of the contested initial history of affirmative action regarding sex discrimination or of LBJ’s record on women’s rights.
This is not an insignificant issue. Wikipedia is widely used by average Americans as a research tool. College undergraduates use it routinely, as do many graduate students. Only PhD or some MA students who are closely supervised by their faculty are likely to know they are missing some important history. Few people, moreover, are likely to question the National Archives as an authoritative source on American history. Executive Order 11246, finally, is hardly the only document where the original does not immediately appear through a Google search. Try finding the original text of the 1966 Freedom of Information Act, for example.
Experienced government information specialists will not be surprised by this and will recognize the need for sophisticated searching (and careful interpretation of search results) in general.
But this is also an example of the importance of our historical collections. Because government information is a record of the activities and attitudes and knowledge of a government at particular points in time, it retains historical value even when it is “out of date” — as in the above example. Different versions of laws, old censuses, series of annual reports, early maps, photographs: all these are important historical records which require the same attention and care we devote to the most current information.
Too often, however, I hear librarians focus on “currency” as a value to such an extent that they seem to deprecate the value of historical records. I feel this is the case when library administrators refer to our historical paper collections as “legacy” collections.
The word “legacy,” when used as an adjective, comes from computing and means superseded, no longer useful, difficult to use, and in need of replacement. In this way the use of “legacy” as an adjective as a description of our historical collections is both incorrect and demeaning. Those who call our historical collections “legacy collections” are diminishing the value of those collections. I don’t know if they do this intentionally or not, but I do know that this use carries an implication that cheapens the value of these collections. That can lead to bad decisions.
If we must use the term “legacy” to describe our historical collections, we should use it as a noun. The noun “legacy” means bequest, heritage, endowment, gift, and birthright. Our historical collections are a legacy from the past to us and to our children and must be treated with respect.
I’ve enjoyed my time as a guest blogger for FGI. To wrap up, I’d like to share a story.
This summer, my household ran smack in to a preservation problem. It all started with fresh paint. My husband started to paint the living room and dining room. A color even, moving us away from 15 years of sensible beige. We were embracing the future. It seems like a good opportunity to have the drapes cleaned. They were old, came with the house, and had a vintage floral theme. They were perfect. But not perfectly preserved, as it turned out. The cleaner called, after testing one panel, to say the lining shredded. Too much sun damage (yes, even here in Seattle). We fussed a bit – considered and abandoned a variety of salvage schemes (for example, cutting the linings out, until we learned the hems shredded as well) – and eventually retrieved the drapes from the cleaner. They have been in the trunk of the car ever since. The rooms are painted now – and look lovely – but the windows are bare.
Our technical services librarian has an interest and expertise in preservation. She’s also a sister crafter, so I consulted her about my dilemma. After telling her the story, she laughed and said “this is just like our library.” And she’s right. The UW Gallagher Law Library has a rich print historical collection of legal and government information. Much of it is falling apart. We are a public institution with a shrinking materials budget. We don’t have the funds to preserve all of the collection, and we can’t afford most of the available digital collections as a substitute for print. So how do we decide? What parts of the collection do we preserve and what do we digitize? Can we salvage anything? Should we buy acid free boxes or just tie volumes? Can some of the fabric become throw pillows? What can we afford to license? Are we headed for a big box store purchase when our heart longs for something we truly cannot afford? Should we go the DIY route, if we can’t afford commercial services? Do we keep our old volumes on the shelves or do we need to empty the trunk of the car to make room for the next thing?
And what do the users want, and how does that impact our decision-making? Our household users (the dogs) didn’t like the disruption of the painting, but they really like looking out the unobstructed window. It’s great for them, actually, since they no longer have to wait for an intermediary with opposable thumbs to open the drapes. They can investigate the world of our street whenever they choose. The intermediaries are fretful, however. We pay the heating bills and know something needs to be done before the damp chill sets in. We think about the future, and the budget. Plus we liked the old drapes. We own them, and we know how to operate them. We don’t like this change, forced upon us by the passage of time.
I’m still wrestling with the drapery dilemma. As for the library dilemma, there is the global picture, which includes digital preservation and consortial arrangements such as LIPA: Legal Information Preservation Alliance, and has been well articulated here on FGI. But I’m interested in the local picture of our library.
I do like the idea that if each individual library works to serve our patron base, and shares what we have, it will, in the end, all work out. My hope is that libraries like ours will ask the right questions. That we’ll thoughtfully consider the answers. That we’ll be good stewards of our resources and try to preserve what’s unique in our collections. That we’ll think about today’s users, and tomorrow’s users, and our role as the largest public law library in the Northwest. Easier said than done, just like a household project. But in the end, it could work.