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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.

FGI comment on GPO RFC re Regional Online Selections Draft Policy

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.

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.

  1. GPO and the FDLP community should jointly develop a national inventory of historical federal publications held in depository libraries.
  2. 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.
  3. FDsys should undergo the Trusted Repository Audit and Certification (TRAC) audit process.
  4. 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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