Disclaimer: This response to the Government Printing Office's Transition Plan was accepted by the Government Documents Round Table (GODORT) Steering Committee on February 5, 1996, and was then forwarded to ALA for approval.

American Library Association
Government Documents Round Table
Response to the Government Printing Office's
"The Electronic Federal Depository Library Program:
Transition Plan, FY 1996 - FY 1998"

23 January 1996

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Introduction | Time Frame | Funding | Access To and Format Of Materials | Preservation | Summation
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The Government Documents Round Table (GODORT) of the American Library Association (ALA) was pleased to have had the opportunity to review "The Electronic Federal Depository Library Program: Transition Plan, FY 1996 - FY 1998." The GODORT applauds the Government Printing Office for proposing this innovative and thought provoking plan to lead the Federal Depository Library Program (FDLP) into a more electronic environment and which will provide the foundation for increased public access to government information by offering new opportunities and mechanisms for the Federal government to share electronic information with the American public.

More than 100 depository librarians and other information professionals from around the country and representing various types of libraries participated in discussions regarding the Plan at the ALA Midwinter meeting in San Antonio, Texas, (19 - 23 January 1996). The following summarizes comments voiced during these discussions. Although the plan contains many positive and far-reaching elements, many librarians had reservations. These concerns were also expressed in the "Resolution Regarding a Transition to a More Electronic Federal Information System" that was approved by the ALA Council.

TIME FRAME
Many in the discussion groups felt that the plan had a better chance of success if it were given five to seven years for implementation. GODORT endorses the concept of a time line but is concerned that the 1998 time frame called for in the Transition Plan is not realistic.

Change to the FDLP has implications for all FDLP partners, including the Superintendent of Documents (SOD), the FDLP libraries, federal government agencies, and the American public. The two-year framework outlined in the Plan provides insufficient time for libraries to plan and solicit at the local level for the necessary budgets adequate to acquire equipment, software, network connectivity, and personnel training that will be required to accommodate the changes to FDLP information delivery brought about by the implementation of the Plan. Similarly, the two-year transition period assumes that the American public is currently capable of using information in multiple electronic formats. Though we agree that information can be very useful in electronic formats, we question whether the preponderance of the public will acquire the requisite skills to use electronic information over the next two years effectively. Recent surveys indicate that fewer Americans are using the Internet than initially reported.

GODORT is also concerned that legislative initiatives identified in the Plan may not be enacted within the two-year time frame. Legislative change is essential to guarantee that federal information presently available through depository libraries will not be lost during or after the transition phase. Similarly, we are concerned that the two-year time frame may be insufficient for the development of inter-agency arrangements between the Superintendent of Documents and federal agencies to guarantee Federal Depository Libraries access to agency electronic information resources. It is also questionable whether standards for information formats necessary to provide efficient and effective public access to electronic federal information can quickly be agreed to.

FUNDING
To accomplish the Transition Plan's necessary stated goal of disseminating critical federal information to the American public, it is vital that Congress appropriate funds for the FDLP at a level sufficient to ensure the Plan's success. GODORT applauds the Transition Plan's innovative re-allocation of existing SOD resources and the use of technology grants to fund depository library needs in a primarily electronic environment. GODORT believes that the current level of funding during the period of transition is critical to ensure continued public access to all public federal information currently available through the FDLP. However, librarians are concerned that under the Transition Plan depository libraries and end users of public information will incur significant additional costs associated with information management, downloading, and printing. Furthermore, no empirical studies have been undertaken to estimate the extent of these additional costs nor to assess the fiscal ability of FDLP libraries to produce the requisite funds.

ACCESS TO AND FORMAT OF MATERIALS
No-fee public access to government information has always been the FDLP's singular most significant contribution to the equitable distribution of federal information throughout the country. Every effort should be made to ensure that this important contribution of the program remains as Congress and Executive offices struggle with the changing nature of cost recovery mechanisms in an electronic environment.

GODORT is pleased that the Transition Plan recognizes that a variety of formats, including paper, are appropriate for the most effective use of federal information distributed to FDLP libraries. While GODORT recognizes the need for a balance between cost and usability, from the perspective of librarians and end users, usability is the most important factor in determining format. Appropriate methods of access are also vital to the successful use of government information. By extending its traditional provision of bibliographic access to government information to include electronic formats also, the SOD will ensure that this information continues to remain accessible to users. Through contact with the library user community, librarians are in a unique position to determine which format and modes of access will be most appropriate for specific information resources. GODORT encourages the SOD to continue an ongoing dialog with the library community regarding information formats.

Statutory guidance must be provided, with adequate enforcement mechanisms, that will instruct agencies that usually charge for access to their public information resources (44 U.S.C. §1902), or make their information available through third parties that charge for access, to arrange with the SOD for no-fee access to their information through FDLP libraries.

PRESERVATION
Many discussion group participants found several of the Transition Plan's essential arguments only reinforced the federal government's responsibility and ability to archive properly and preserve government information in electronic formats for long-term access.

To minimize data loss in a dynamic electronic environment, GPO must have a legislative agenda that includes revision of the United States Code to:

* place in GPO authority and responsibility to archive public information that has been held traditionally in Regional Depository Libraries;
* require federal agencies to transfer custody of public electronic information to the SOD for long-term access when the agency's immediate need no longer exists;
* provide the SOD with a strong enforcement mechanism;
* shift to the SOD the legal responsibility for transferring public electronic information to the National Archives and Records Administration (NARA); and
* establish federal government authority of information produced through private sector/agency partnerships and require that this information be transferred to NARA for historical preservation.

While it is the responsibility of the NARA to preserve government information in perpetuity, many depository libraries have preserving, archiving, and migrating public information to useable formats as part of their mission. Their ability to do this, and thereby ensuring no-fee public access, should not be inhibited by agency restrictions on downloading or secondary distribution of data files.

Mirror sites for information in the custody of the SOD for long-term access must be established through partnerships or cooperative agreements with depository libraries, libraries, state agencies, research institutions, and regional networks. The contractual agreements that establish the partnerships should specify no-fee access for federal depository libraries and provisions for transfer of the information to the SOD should the partnership dissolve.

SUMMATION
GODORT approves of the general direction, if not the pace and all the details, of the Transition Plan. GODORT and GPO share the same goals of no-fee public access and fair, efficient, and equitable dissemination of government information for the citizenry. Working together we can realize these goals in the more electronic Federal Depository Library Program.


Go to: Resources of Use to Government Documents Librarians ..........

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Western Kentucky University Libraries
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February 5, 1996
Revised September 10, 1997
URL: http://www2.wku.edu/library/dlps/response.htm