[net-gold] FGI Reaction to CRS FDLP Report
- From: "David P. Dillard" <jwne@xxxxxxxxxx>
- To: Net-Gold -- Educator Gold <Educator-Gold@xxxxxxxxxxxxxxx>, Educator Gold <Educator-Gold@xxxxxxxxxxxxxxxx>, net-gold@xxxxxxxxxxxxx, Net-Gold <Net-Gold@xxxxxxxxxxxxxxx>, NetGold <netgold@xxxxxxxxxxxxxxx>, Net-Gold <net-gold@xxxxxxxxxxxxxxxx>, K-12ADMINLIFE <K12ADMIN@xxxxxxxxxxxxxxxxxxx>, K12AdminLIFE <K12AdminLIFE@xxxxxxxxxxxxxxx>, MediaMentor <mediamentor@xxxxxxxxxxxxxxx>, NetGold <netgold@xxxxxxxxxxxxxxxx>, Net-Platinum <net-platinum@xxxxxxxxxxxxxxx>, Sean Grigsby <myarchives1@xxxxxxxxxxxxxxx>, Net-Gold <NetGold_general@xxxxxxxxxxxxxxxxx>, Temple Gold Discussion Group <TEMPLE-GOLD@xxxxxxxxxxxxxxxxxxx>, Temple University Net-Gold Archive <net-gold@xxxxxxxxxxxxxxxxxxx>, Health Lists -- Health Diet Fitness Recreation Sports Tourism <healthrecsport@xxxxxxxxxxxxxxxx>, Health Diet Fitness Recreation Sports <healthrecsport@xxxxxxxxxxxxxxx>, HEALTH-RECREATION-SPORTS-TOURISM@xxxxxxxxxxxxxxxxxxx
- Date: Tue, 17 Apr 2012 04:54:21 -0400 (EDT)
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The message below my signature lines is reposted with the permission of
the author of the post.
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Sincerely,
David Dillard
Temple University
(215) 204 - 4584
jwne@xxxxxxxxxx
http://workface.com/e/daviddillard
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Date: Mon, 16 Apr 2012 02:40:12 -0800
From: Daniel Cornwall <danielcornwall@xxxxxxxxx>
To: GOVDOC-L@xxxxxxxxxxxxx
Subject: FGI Reaction to CRS FDLP Report
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Fellow Govdoc'rs
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My colleagues and I at Free Government Information read through and
discussed the latest Congressional Research Service report on the
FDLP. Here are thoughts we came up with and posted to
http://freegovinfo.info/node/3672:
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We have had a chance to review the new Congressional Research Service
(CRS) Report Federal Depository Library Program: Issues for Congress
(Petersen) available at from the Federation of American Scientists,
Project On Government Secrecy web site.
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While we believe it serves as a useful overview of the Federal
Depository Library Program (FDLP), the report has a few significant
problems. Members of Congress should consider the following before
using this report as a basis for modifying the FDLP:
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REPORT APPEARS TO TAKE ITHAKA S+R AT FACE VALUE
Pages 6-11 of the CRS report concern the findings of the Government
Printing Office (GPO) commissioned Ithaka S+R FDLP Report
(Housewright) and GPO's ultimate rejection of the report. We are
concerned that CRS has taken Ithaka's conclusions at face value and
have not considered the many criticisms of the Ithaka report. Some of
these criticisms included:
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•The report made broad statements about users without sufficient
consultation with actual end users.
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•The report focused on the value of the program to libraries and not to users.
•The report apparently ignored corrections from law librarians and
others so that errors in draft documents carried over to final
documents.
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•The report excluded serious discussion of digital deposit and local
digital collections of federal information.
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•The report failed to account for risks of implementing its recommendations.
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We wrote extensively during the Ithaka S+R report period. We were not
alone. A complete set of comments that Ithaka S+R received on its
project web site is available from GPO. Yet the CRS report authors do
not appear to have considered the public comments that questioned a
number of Ithaka S+R's findings.
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Another curiosity is CRS's omission of GPO's reasoning for rejecting
the Ithaka S+R report. The authors simply note that "GPO did not
provide a detailed, publicly available explication of its decision."
It seems to us that it would have been appropriate and useful for CRS
to have contacted Superintendent of Documents (SuDoc) Mary Alice Baish
and interviewed her about GPO's rejection of the Ithaka S+R report. In
doing so, CRS could have expanded the existing public record with more
details from GPO as to why the report was unacceptable and given the
report an additional depth of understanding. Given the GPO rejection
of the Ithaka S+R report and the amount of criticism of the report
from the library community, CRS's reliance on the report results in a
description of the FDLP that is both limited and slanted.
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THREATS TO ACCESS TO DIGITAL GOVERNMENT INFORMATION
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Pages 13-14 of the CRS report address "Access to Digital Government
Information." The section concludes with the following:
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The use of the FDLP Electronic Collection may raise the following
concerns in the context of digital information:
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•Where do FDLP Electronic Collection data reside?
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•Are current data management protocols sufficient to ensure no loss of
data availability, and assured access?
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•Are those protocols similar in GPO, other federal agencies, and non
governmental partners that provide content?
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•What backup, and information distribution and assurance policies,
are in place?
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Although these are legitimate questions, CRS left out bigger problems
within which these questions are merely details of implementation.
These bigger problems stem from the GPO-centric model of the FDLP in
which GPO has usurped from libraries the roles of both preservation
and access. By replacing libraries, GPO has endangered the long-term
future of information preservation and free-public access to that
information in many ways. Three of the most important of those are,
uncurated access, the term we call "silent withdrawals," and the very
real potential of inadequate funding of GPO along with the
complementary danger of replacing of free access with fee-based
access.
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UNCURATED ACCESS
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Access to government information has been a key tenet of the FDLP for
200 years. CRS averred that fact when they stated, "emergence of
digital delivery of government information outside the FDLP program
may offer increased access to government information to those who
might not be able to visit depository libraries." But the key point
missed by CRS is the idea of uncurated access. By only discussing
access, but not preservation, CRS ignores the processes carried out by
depository institutions to *preserve* govt information. We have said
many times on FGI that access today does not equal access in the
long-term. Libraries have begun to put processes in place to assure
long-term digital access (University of North Texas Digital Library,
LOCKSS-USDOCS, Archive-it collections, End-of-term crawls etc).
Librarians can and should continue their curatorial responsibilities
in the digital realm. We can't expect GPO and other government
agencies -- especially in this budget crisis climate -- to have the
long-term vision necessary to assure long-term preservation. Curation
and content control will be key issues going forward. These issues
were merely glossed over by the report.
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SILENT WITHDRAWALS
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One of the many strengths of a distributed depository system is the
way its very structure protects information from intentional or
unintentional loss, censorship, or erasure. Without this protection,
information can too easily be withdrawn "silently" -- that is, without
public announcement or review. That FDLP works is evident when one
compares information in the depository system to information not in
the depository system. The number of documents that have been sent to
depository libraries and later withdrawn is relatively small and the
reasons for the recalls are usually not controversial.
•Federal publications recalled from libraries. (1981-2010). Stanford
University Library.
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Contrast this to information that has been withdrawn from the web,
reclassified by agencies, and documents that have had open access
restricted by agencies after their release:
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•Less Access to Less Information By and About the U.S. Government (1981-1998).
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•Chronology of Disappearing Government Information (1998-2002),
Compiled by Barbara Miller for ALA/GODORT Education Committee With
special assistance of Karrie Peterson.
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•No URL Left Behind? Web Scrub Raises Concerns, by Michelle R. Davis,
Education Week, 22:3 (9/18/2002), 1-2.
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•Homefront Confidential. Reporters Committee for Freedom of the
Press, Sixth edition (September 2005)
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•The Age of Missing Information. By Steven Aftergood, Slate (March 17, 2005).
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•Army Blocks Public Access to Digital Library, by Steven Aftergood,
Secrecy News (February 13th, 2008).
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•DOD withdraws embarrassing report, FreeGovInfo (2009-05-13).
•Secrecy Report 2011. OpenTheGovernment.org.
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The reason for the success of the depository system is that it has
checks and balances and procedures that must be followed when an
agency wishes to withdraw a publication ("ID 72" GPO 2005). In the
world of physical deposit of print documents, withdrawal of a
previously deposited document requires the compliance of tens or even
hundres of libraries that actually have physical possession and
control of copies. While depository librarians have a legal obligation
to comply with withdrawal and destroy orders, there have been cases
where this step triggered complaints about unreasonable withdrawal
requests. Such questioning has led agencies to withdraw requests that
seemed based on embarrassment or paranoia rather than error or true
security needs.
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One noteworthy example of this comes from 2001 when the CIA put
pressure on the Department of State to destroy already-printed volumes
of the Foreign Relations of the United States, 1964-1968, V. 16,
Cyprus, Greece, and Turkey. But those volumes were in the possession
of GPO and slated for deposit with FDLP libraries (Aftergood). The
volumes were not destroyed and were distributed (S 1.1:964-68/v.16).
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Another example comes from 2004 when the Justice Department demanded
that depositories destroy copies of five publications that dealt with,
among other things, how citizens can retrieve items confiscated by the
government. The American Library Association objected, the Justice
department rescinded its order, and GPO allowed libraries to keep
copies and also replaced copies already destroyed. (Lee)
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GPO's policy does have good procedures to prevent "silent withdrawals"
even of information that is not physically deposited with libraries.
But when GPO does not deposit digital copies with libraries,
depositories are cut out of the procedures and an important safeguard
is missing. Withdrawal decisions and their execution stay wholly
within the federal government -- making it easier for the government
to remove items from public access. The "LOCKSS-USDocs" private LOCKSS
network project is beginning to replace this safeguard, but more work
is needed to ensure digital deposit with more libraries in order to
guard against silent withdrawals.
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BUDGET PROBLEMS
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The current GPO-centric model of digital access described, and
apparently unquestioned, by CRS has a single point of failure. If
Congress decides it is no longer worthwhile to adequately fund
information dissemination in general or GPO in particular, users and
libraries will lose access to material unique to GPO's servers. Even
the maintenance of so-called "persistent" URLs (PURLs) could be
endangered by something as simple as inadequate funding.
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Digital information requires long-term, consistent funding. Neither
digital information preservation nor access can be accomplished
passively: both require constant attention and renewal and resources.
Even budget cutbacks can cause loss of information or loss of access
to information. The single-point-of-failure GPO-centric model of
preservation and access is a system in which even inadequate funding
means loss of information.
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Reduced funding can also lead to privatization of government
information access. This can occur if the fee-based private-sector
takes over the delivery of services that GPO drops because of
inadequate funding. It can also occur if Congress mandates that GPO
use a fee-for-service model. In both cases, free access will be lost
and people and libraries may be unable to afford adequate access.
(Jacobs)
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An April 10, 2012 Federal Times demonstrates that GPO is already
feeling a lot of pain:
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"At risk of needing a congressional bailout 18 months ago, the
Government Printing Office slashed its workforce, cut employee
benefits, rented out excess office space and took other steps to
stabilize its finances."
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To make ends meet, GPO is also focusing on money-making activities
like making secure credentials for the FBI. At its heart, the FDLP is
a cost center. It has no opportunity to make GPO profit. This is right
and proper, but will continue to make the FDLP a tempting target in
future budget reductions. (Jacobs)
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SUMMARY
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Any discussion of disruptions in user access needs to acknowledge the
above facts. As long as digital storage is centralized in GPO, free
and permanent access is only a Congressional Act away from being
disable or terminated. The report does ask a key question: what
solutions might create a more robust FDLP that is better equipped to
meet the demands of providing government information to American
citizens." We at FGI and many allies in the FDLP community have been
working on that question (see Letter to Deputy CTO Noveck: "Open
Government Publications," Rethinking the Cloud, and Achieving a
collaborative FDLP future to contextualize the issues involved).
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The report written by Petersen, Manning and Bailey provides a useful
historic overview of the FDLP. We feel that it somewhat
mischaracterizes recent efforts at building consensus. Most seriously,
the report leaves out major barriers to free, permanant public access
to government information that MUST be addressed in any meaningful
reform effort.
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REFERENCES
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•Aftergood, Steven. State Dept Mulls "Book Burning." Secrecy News
(September 21, 2001)
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•Housewright, Ross, and Roger C. Schonfeld. Modeling a Sustainable
Future for the United States Federal Depository Library Program’s
Network of Libraries in the 21st Century, Final Report of Ithaka S+R
to the Government Printing Office, Ithaka S+R, May 16, 2011, Including
"Statement from the U.S. Government Printing Office" by Mary Alice
Baish (August 5, 2011)
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•Jacobs, James A. Privatization of GPO, Defunding of FDsys, and the
Future of the FDLP, FreeGovInfo (2011-08-11).
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•Lee, Christopher. Justice Dept. Rescinds Order to Pull Publications.
Washington Post (August 5, 2004) page A17.
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•Lipowicz, Alice. Digital information may strain GPO and library
system, CRS says, Federal Computer Week(Apr 11, 2012)
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•Petersen, R. Eric, Jennifer E. Manning, and Christina M. Bailey.
Federal Depository Library Program: Issues for Congress by Petersen,
Congressional Research Service CRS Report R42457 (March 29, 2012)
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•Reilly, Sean. Cost-cutting saves GPO from financial crisis, chief
says. Federal Times, (4/10/2012).
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•Replacement copies of five DOJ documents for depositories that had
removed them. Judith C. Russell, Superintendent of Documents (August
5, 2004)
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•U.S. Government Printing Office. Managing Director, Information
Dissemination, Superintendent of Documents. Information Dissemination
Policy Statement 72 (ID 72). "Withdrawal of Federal Information
Products from GPO’s Information Dissemination (ID) Programs."
Effective Date: June 21, 2005, Supersedes No.: SOD 72 Dated: 07/22/02.
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•LOCKSS-USDOCS private LOCKSS network: The Digital Federal Depository
Library Program.
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Daniel Cornwall
State Agency Databases Across the Fifty States / Free Government Information
danielcornwall@xxxxxxxxx
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