February 17, 2018

The Future of the FDLP: From Conversation to Confrontation

By Jim Jacobs and Melody Kelly

Recent discussions about the state of the Federal Depository Library Program (FDLP) and the responsibilities of regional depository libraries have morphed from a conversation into a politicized confrontation. Sadly, this threatens to negatively affect not just depository libraries but all libraries and users who rely on a robust FDLP for long-term free access to government information.

While the issues are clear, the confrontation has muddied the waters considerably. We once had a cooperative discussion of how to balance existing legal requirements with a shared goal of moving to a better, digital FDLP. We now have personal attacks on the leaders of the Government Printing Office (GPO) and the FDLP, suggestions to change the legal foundation of the FDLP (USC Title 44), and arguments that are focused on the narrow agenda of a few large research libraries. These divisive, dramatic tactics impede finding common solutions to shared problems.

The Association of Research Libraries (ARL) and the Association of Southeastern Research Libraries (ASERL)—with letters of support by other library organizations in which members of the ARL participate—claim to have discovered a problem so immense that it threatens the very existence of the FDLP and are making assertions that are at best questionable and at worst just plain false.

At the root of the controversy are two proposals—one [PDF] by the directors of regional depository libraries at Michigan State Library and University of Minnesota, and another [PDF] by ASERL. The proposals would reduce the number of paper copies preserved by FDLP by consolidating paper collections and by providing access to digital copies rather than paper copies.

There are four fundamental problems with these proposals.

First, in 2008, the Congressional Joint Committee on Printing (JCP) denied a proposal that would have allowed two regionals in Kansas and Nebraska to share a single collection. It is JCP’s decision—not GPO’s leadership—that is making this a long-term issue that cannot be solved by short-term demands by a few big research libraries. The right thing to do is to develop an alternative that would be acceptable to JCP (such as using the existing FDLP model of shared or “selective storage” locations within each state).

Second, the ASERL proposal would rely on digital copies of printed publications without addressing the need for authenticating those digital surrogates. Failing to address authentication will endanger the reliability of our digital collections. The FDLP community can work with GPO to develop procedures to solve this problem without changing the US Code. Creating a political battle over this issue could easily result in solutions designed by Congress, not by information professionals.

Third, both proposals assume we can rely on digital surrogates as access-substitutes for existing paper collections. Existing studies of digitization cast doubt on this assumption: many government publications are old and brittle and include more than text; accurate digitization of statistical tables is very difficult and prohibitively expensive with current technologies. While digital surrogates of paper may serve the needs of many users, libraries will still need an adequate number of paper copies for direct user examination when digitization is flawed or inaccurate and for re-digitization with better technologies in the future. We just do not yet have the information we need that would justify the proposed drastic weeding of our valuable paper collections after digitization.

Fourth, the proposals seek to minimize the number of paper copies stored in the FDLP system without first determining how many paper copies are needed for preservation and access. Preliminary studies of this issue do not adequately address the special nature of government publications, assume we will have perfect digital copies to supplement paper copies, and seek only to preserve non-circulating paper copies. The issue of weeding our valuable collections is about access as well as preservation. It is not just about keeping an emergency copy-of-last-resort in a vault or about Title 44 legal requirements. It is about keeping an adequate number of working, usable, loanable copies geographically near their users. A mistake in judgment at this point would result in irrevocable loss of information.

The underlying justification of these proposals is that libraries can lower their costs by weeding their collections. Although reducing costs is laudable if it is a result of increased efficiencies, it is questionable if it results in damaging our collections or neglecting our services.

There is no doubt that Regional and Selective FDLP libraries alike face difficult challenges, e.g., digital authenticity, digital deposit, digital preservation, disintermediation, changing priorities of participating libraries, etc. We need to work together to solve these challenges through cooperative ventures and consensus regarding how best to revise existing rules and procedures. But if the community fragments, we can be certain that, no matter who “wins,” there will also be losers. The users of government information will be the ones most hurt by such political battles and infighting. Politics only weakens the GPO and the FDLP at a time when both need all of our support, collaboration, and ingenuity to face these difficult challenges.

Author Information
Jim Jacobs is Data Services Librarian Emeritus at the University of California, San Diego, and Melody Kelly is Adjunct Professor at the College of Information at the University of North Texas, Denton. Submissions for Backtalk should be 850 to 900 words and sent to Michael Kelley at mkelley@mediasourceinc.com