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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.
A new paper by Bernadine E. Abbott Hoduski and Michele McKnelly addresses the proposal to revise Chapter 19 of Title 44 “to allow a more flexible structure” for Regional Depository Libraries.
- Does the Federal Depository Library Program Require Title 44 Revision to Improve Public Access to Government Information?, by Bernadine E. Abbott Hoduski and Michele McKnelly, December 2, 2008
Hoduski and McKnelly conclude that the proposal “will do more harm than good and alternatives that will improve public access should be considered.”