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Last fall, GPO announced a new Superintendent of Documents (SOD) draft policy statement “Regional Depository Libraries Online Selections.” GPO surveyed regional depository libraries and released the results of that survey in February, 2021. They’re also asking the wider library community and interested parties for comment DUE MAY 16, 2021.
FGI has submitted a comment regarding this proposed policy change. Below is the text of our comment. In short, this policy change could negatively impact the preservation of and long-term access to the National Collection. Our suggestion was to change the policy and add a “digital deposit” requirement:
“Regional depository libraries may select “online” as a format IF AND ONLY IF regionals participate in a “digital deposit” program and agree to receive, host, and provide access to digital FDLP publications.”
We hope others will submit comments BY MAY 16, 2021!
Thank you for requesting comments from the Federal Depository Library community for this proposed major policy change for regional library collection management.
Suggested edit of draft policy:
“Regional depository libraries may select “online” as a format IF AND ONLY IF regionals participate in a “digital deposit” program and agree to receive, host, and provide access to digital FDLP publications.”
We at FGI have 2 concerns regarding this proposed policy change.
The first concern has to do with the current practice described in the background section of the proposed SOD:
“…they [regionals] no longer are receiving all new and revised tangible versions for all titles through the FDLP. Nor are regional depository libraries necessarily retaining a printed or microfacsimile version of what they receive.”
According to 44 U.S. Code § 1912, Regional libraries are required to receive and “retain at least one copy of all Government publications either in printed or microfacsimile form.” How many regional libraries are no longer following the requirements of the statute? What is GPO doing to assure that the letter and spirit of Title 44 are being followed by regional libraries? Rather than codifying this bad behavior, GPO should be doing more to help regionals fulfill the requirements of the statute and assure the long-term viability of the FDLP for all of the libraries and the wider public that rely on regionals. Any proposed SOD should seek to correct this unfortunate situation.
Our second concern has to do with the proposed policy change itself.
“Regional depository libraries may select “online” as a format, without having to make a corresponding tangible selection, for titles or series accessible through GPO’s system of online access, a trusted digital repository, or from official digital preservation steward partners.”
One of the primary functions of regional libraries is to participate in the long-term preservation of US government publications. Indeed, retention (ie., preservation) is written into 44 U.S. Code § 1912 itself. Selective libraries across the country rely heavily on this regional requirement to manage their FDLP collections.
The existing law is clear: “In addition to fulfilling the requirements for depository libraries” regional depositories must “retain at least one copy of all Government publications either in printed or microfacsimile form (except those authorized to be discarded by the Superintendent of Documents).” The only other mention in the law of the Superintendent being able to authorize discarding is for “superseded publications or those issued later in bound form which may be discarded as authorized by the Superintendent of Documents” (§ 1911).
As the Senate Report on the bill stated, “Complete document collections would thus be accessible to all the regular depositories within the State, enabling them to be more selective in the items they would request” (S. Rep. 1587, 87th Cong., 2d Sess. 1962). The legislative history is clear that the establishment of Regional Depositories was designed both to allow selectives to discard publications after five years and to ensure that all publications would be available from a Regional.
The law has not changed and this policy would contradict both the letter and intent of the law.
Although GPO continues to promulgate policies that wrongly equate “online access” with “deposit,” no change in the law allows this. We welcome online access and the efforts GPO is making to ensure preservation of digital government information, but, as GPO’s draft policy says, the policy is rooted in the past, in choices made twenty-five years ago. It would be wiser and more sustainable to base new decisions in the current and developing capabilities of FDLP libraries rather than on the past. We suggest that there is a better path that conforms to the existing law, enhances preservation, and improves access and use of digital government information. Our suggested edit looks to a future of GPO and FDLP libraries collaborating together to preserve and give access to the National Collection.
We suggest that, until Title 44 is changed, GPO should choose a simple and effective alternative that will accomplish more than GPO’s proposal.
We recommend a policy of allowing a regional depository to choose digital copies of government publications (instead of printed or microfacsimile) IF AND ONLY IF it agrees to actually receive, host, and provide access to those digital files. The SOD could do this by, for example, making regional selection and deposit format-agnostic or adding digital formats to the list of currently anachronistic “tangible” formats.
Our suggestion begins by respecting the existing law, which mandates that multiple copies of government publications be held for both preservation and access by libraries outside the government. For “access” our suggestion will allow libraries to provide digital services for specific designated communities. For preservation, it ensures against intentional or unintentional loss of access, corruption of content, or outright loss of information in the government’s care.
Our suggestion is also compatible with the work of the The Digital Deposit Working Group of the Depository Library Council (on which James is participating), which is currently working on recommendations for digital deposit based on FDLP community feedback which would directly contradict GPO’s proposed regional policy. Our proposal looks to a future of digital deposit. Indeed, ten regional libraries are already receiving and preserving all content published in govinfo.gov through the LOCKSS-USDOCS program. Our proposal provides GPO the opportunity to create a policy that will lay a solid foundation for the digital FDLP, increase participation by FDLP libraries, and enhance services for the National Collection.
It has long been established that the preservation of born-digital government information is a challenging endeavor. It also should be clear that a one-size-fits-all model of “access” without digital services is inadequate in the digital age. GPO cannot and should not go it alone. GPO needs multiple partners to participate in digital preservation and in the provision of digital services.
GPO’s proposed SOD, rather than strengthening the long-term viability of the digital FDLP, erodes its very foundation by literally erasing the critical, legislatively-required job for which regionals were created. Any library or individual can do what the draft SOD suggests (point to govinfo.gov), but FDLP libraries could do so much more. They can complement what GPO does by providing official, legislatively-mandated, redundant preservation, and by providing enhanced digital services targeted to specific OAIS designated communities.
There’s something that has been sticking in my craw for quite some time. That something is the term “flexibility” that has been used as a bludgeon by regional FDLP libraries to push the Government Publishing Office (GPO) to create its potentially disastrous regional discard policy. Over the last 5 years at least, some FDLP librarians — primarily those in Regional libraries — have argued that, because of dire space issues at their libraries, they need “flexibility” to manage their collections. In other words, they want to discard documents to gain floor space. Regionals have argued that Title 44 of the US Code, the underlying law of the FDLP, does not give them this “flexibility.”
It’s always bothered me that this demand for “flexibility” has come from a few regionals but the policy change will affect the whole FDLP. When GPO asked regionals what they wanted to do, more than half of the 47 current Regionals said they wanted to retain their current tangible collections and sixty percent said they wanted to continue building their tangible collections. When, in the same survey, GPO asked which of 60 specific titles Regionals might want to discard, only two titles were selected by more than a third of regionals.
So, if a few Regionals want to get rid of a few titles, why do we need a policy that turns the FDLP commitment to preservation upside down and encourages rather than prohibits discarding at all 47 Regionals?
It seems to me that there are three problems with the argument that Regionals need “flexibility:”
- The FDLP system already has flexibility. There are two kinds of depository libraries: Regional libraries that are required to receive all publications that GPO distributes in order to ensure long term preservation and access to the entire FDLP corpus and support the work of Selective libraries in their state or area, and Selective libraries that tailor their collections to match their size and the needs of their local communities and which may withdraw documents they’ve selected after 5 years’ retention. It is the very rules that the Discard Policy circumvents (Title 44 and the The Federal Depository Library Handbook) that create and support the flexibility of the system as a whole. The retention requirement of regionals is the very reason that all selective FDLP libraries can discard and manage their collections “flexibly.”
- Flexibility is built into the FDLP. Indeed, the words “flexibility” and “flexible” are mentioned more than a dozen times in the FDLP Handbook. This new (mis)use of the term to mean only one thing — discarding paper copies by Regionals — is a red herring that implies that flexibility is needed (it is not) and does not exist (it does). If a few regionals need “flexibility” perhaps they should just become selectives.
- Giving Regionals the “flexibility” to discard parts of their collections actually reduces the flexibility of the system as a whole because it puts new burdens on the Selectives — thus reducing their flexibility.
Is the current Regional/Selective FDLP system perfect? No, there’s lots more work to be done by all FDLP libraries to assure preservation of the historic national collection and better support the program, and more that GPO could do to support cataloging and curation of the national collection. But I really wonder if the FDLP even needs this new designation of “preservation stewards” brought about by the introduction of the Federal Information Preservation Network (FIPNet) and the Regional Discard Policy. We already have 47 of them in the form of Regional libraries! If a few regionals choose to become selectives, FDLP would still have all those other Regionals (maybe as many as 40?). And we would also have those few former-regionals that would probably maintain most if not all of their historic collections. This would be much better for preservation and better for users than these temporary preservation stewards.
Last month, the Government Publishing Office (GPO) released the National Plan for Access to U.S. Government Information: A Framework for a User-centric Service Approach to Permanent Public Access. The National Plan is the culmination of four years of study and planning activities conducted by GPO’s Library Services & Content Management (LSCM) in response to a range of factors that include directives from the Joint Committee on Printing (JCP) and the National Academy of Public Administration; seismic changes in government publishing and user information access practices; and the shifting mission of large academic research libraries.
For those interested in the background to the National Plan, I summarized some of the available information a few months ago. While a detailed development process is not included in the final document, GPO repeatedly solicited quantitative and qualitative data from depository libraries, most notably in its 2012 FDLP Forecast Study, as well as through the Biennial Survey process. GPO has already shared much of the information found in the National Plan in presentations to the community over the past year. As of this writing there is no public comment or feedback process; however, several of the sessions on the preliminary schedule for next month’s Depository Library Council virtual meeting pertain to the implementation of the National Plan, including presentations on public libraries, regional models, and the regional discard pilot project.
I recognize that there can be some hesitance in the depository librarian community in discussing a document like this in detail. After all, criticisms of the National Plan are functionally critiques of LSCM’s strategic direction, and by extension can be (mis)interpreted as criticisms of GPO and its leadership. In preemptive response, I agree with the FGI team: respectful, timely discourse makes our community stronger. I believe wholeheartedly that we all want a similar future: one in which government information is available for all to use and reuse, whenever and wherever it is needed. The vision and mission for the National Plan reflects this desire, as do the words and actions of the GPO staff who put the words into action. LSCM has been and continues to be uniquely positioned to coordinate and accomplish this work, and they have made commendable progress on many initiatives that will contribute to public access to government information for generations to come.
Like all FGI occasional contributors, I’m speaking only for myself, not my place of work, my library consortium, or the FGI team. But with that disclaimer out of the way, I think this document is an opportunity for depository librarians and others who care about future access to government information to identify where voices from the community can and should speak up to ensure that planned activities and initiatives are in alignment with the aspirational goals of sustaining permanent no-fee public access to government information. Our responsibility as a community to make sure that the promise of access is one that will be fully met through collaborative work with each other and engagement with GPO.
Structure and Format
GPO should be commended for producing a document that we can read, discuss, and share with others who care about government information. This is GPO’s plan for action and activities undertaken by LSCM: the National Plan contextualizes current priorities and initiatives, and provides a roadmap for where to expect LSCM’s focus to be going forward. It is also described as a ‘flexible framework,’ which suggests that the exact work to be conducted is yet to be determined, although several projects are underway and some are in the planning stages.
The core of the National Plan is the section of “Desired Outcomes and Actions,” which are based on a list of “Drivers of Change” that include the results of the 2012 FDLP Forecast Study, recommendations from the 2013 NAPA report on GPO commissioned by Congress, and a short but wide-ranging list of external influences. Each outcome is mapped to one of the “Principles of Government Information” adopted by GPO in 1996. Additional assumptions are also articulated that reflect the list of external influences.
The National Plan also presents three strategic priorities: lifecycle management of government information within LSCM to ensure permanent public access to digital government information; development of a sustainable structure for the FDLP; and the delivery of services that support depository libraries in providing accurate government information to the public in a timely fashion. While the strategic priorities relate to the “Drivers of Change,” they are not explicitly mapped to the vision and mission of the National Plan.
The language used throughout the National Plan is that of access rather than preservation. It is clear that enabling permanent public access to information is not the same as preserving information products, though the two go hand in hand. In general, the National Plan references concepts already in common usage in the community without further explanation. For example, there are no assumptions explicitly defining key terms like ‘access’ and ‘sustainability,’ but the concepts are used throughout the document.
To a certain extent, the National Plan is difficult to unpack and discuss because it is deeply non-specific. This lack of specificity has a particularly strong effect on action items pertaining to preservation. Of the six action items, three simply reference new programs (FIPNet, an LSCM Preservation Program, and a project to inventory “copies of record”), one pertains to access rather than preservation (working with partnerships to digitize the historical tangible collection), one relates to the development of guidelines, and one is to increase the profile of government information preservation at the national level. So although the reciprocal relationships between preservation and access are addressed in some ways, outcomes that reflect the government’s obligation to preserve its information are not fully articulated or supported.
Actions categorized as pertaining to right of access, dissemination of information, and authenticity are more specific, but the mapping of outcomes to principles is unclear. If this were to be the only public documentation guiding LSCM’s activities, then the community would have little insight into what GPO is trying to accomplish and why. As more detailed strategies and implementation plans are developed — I hope in consultation with the community at large — and disseminated, it should be possible to more confidently identify the extent to which a given action item will contribute to any given desired outcomes that can be mapped to shared goals and expectations.
The National Plan continues to frame depository libraries as supporters of public access rather than participants in the long-term management of government information, reflecting a broad and ongoing shift of framing libraries as service providers rather than collectors and organizers. Because the Regional discard policy has been approved and is currently in the implementation phase, we know that publications with authenticated digital versions in FDsys (and its successor, govinfo.gov) are eligible for Regional depository libraries to withdraw and discard under the oversight of the Superintendent of Documents. Other action items in the National Plan will lead to the ingest of more content into FDsys from depository libraries and third parties, and the authentication of this digital content, which makes more collections digitally accessible but also eligible for discard in print, a shift that could have a substantially negative effect on long-term access. An additional action item investigates the possibility that Regionals could decline to select certain materials in print/microformat altogether, and another identifies the development of requirements to facilitate pushing or depositing digital content to libraries.
While increased access to authenticated digital surrogates is a laudable measure for public access, taken as a whole the actions identified in the National Plan are framed by a continued shift of the responsibility for collection-building and preservation away from FDLP libraries, without introducing a clearly defined and workable alternative for the long-term preservation of print collections, and without adding the expectation of a meaningful role in digital preservation for these same institutions. (FIPNet is intended to fill this role, but as of this writing, this program is still mostly undefined.) The only action item directly addressing print collections in depository libraries is the development of collection care training for depository staff, and it is categorized as an action related to authenticity and integrity rather than preservation.
In general, changes to the FDLP are incorporated in the National Plan under the principle of disseminating government information, with a specified outcome of forming a sustainable network structure and governance process for the efficient management of depository collections and services. Depository libraries are only a small segment out of many potential public access channels, albeit a segment best poised to serve both marginalized and specialized users, and the National Plan identifies the need for LSCM to play a greater part in lifecycle management of information dissemination products within the federal government. However, under the National Plan, the alternatives for preservation outside of the depository library system are, at present, unclear.
Because the document is describing the role LSCM will adopt and the work it will accomplish, rather than a revised strategy for the FDLP as a program, the National Plan is not GPO’s definitive statement on the future of the FDLP. Based on this document, however, it seems reasonable to predict that GPO’s articulation of its vision for the future FDLP will reflect the priorities established in this document. With that understanding, presenting the National Plan as a document is in itself a significant step in the right direction because it gives the government information community a shared frame of reference in discussing GPO’s priorities and evaluating its accomplishments, and provides us with the opportunity to determine how our libraries and organizations, as well as the community as a whole, can respond to and engage with GPO initiatives as they move forward.
James A. Jacobs. “NAPA Releases Report on GPO.” http://freegovinfo.info/node/3862. Updated February 6, 2013.
James A. Jacobs and James R. Jacobs. “What You Need to Know About the New Discard Policy.” http://freegovinfo.info/node/10525. Updated November 30, 2015.
James R. Jacobs. “DLC Responds to Open Letter Regarding the New Regional Discard Policy” http://freegovinfo.info/node/10736. Updated January 18, 2016
Library Services & Content Management. “FDLP Forecast Study.” http://www.fdlp.gov/377-projects-active/1686-fdlp-forecast-study. Updated August 12, 2015.
—. “Federal Information Preservation Network.” http://www.fdlp.gov/project-list/federal-information-preservation-network. Updated April 13, 2015.
—. “Federal Information Preservation Network (FIPNet) – Answering Your Questions.” http://www.fdlp.gov/all-newsletters/featured-articles/2349-federal-information-preservation-network-fipnet-answering-your-questions. Updated December 21, 2015.
—. “JCP Approves Regional Discard Policy.” http://www.fdlp.gov/news-and-events/2403-jcp-approves-regional-discard-policy. Updated October 22, 2015.
National Academy of Public Administration. Rebooting the Government Printing Office: Keeping America Informed in the Digital Age. https://www.gpo.gov/pdfs/about/GPO_NAPA_Report_FINAL.pdf. January 2013.
Office of the Superintendent of Documents. National Plan for Access to U.S. Government Information: A Framework for a User-Centric Service Approach to Permanent Public Access. http://www.fdlp.gov/file-repository/about-the-fdlp/gpo-projects/national-plan-for-access-to-u-s-government-information/2700-national-plan-for-access-to-u-s-government-information-a-framework-for-a-user-centric-service-approach-to-permanent-public-access. February 2016.
Shari Laster. “Information Sharing and the National Plan.” http://freegovinfo.info/node/10569. Updated November 12, 2015.
—. “One Year Later…What’s Happening with Regionals and Discards?” http://freegovinfo.info/node/10285. Updated September 8, 2015.
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.
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.
Bernadine Abbott Hoduski
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
Lawrence R. (Larry) Meyer
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