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Dear Ms. Russell,

Thank you for the opportunity to comment on the discussion draft of “Collection of Last Resort (CLR).” The American Library Association’s Government Documents Round Table (GODORT) commends the Government Printing Office (GPO) for taking this crucial step in ensuring permanent public access to government publications. The preservation of this information, especially those publications that are born digital, is essential to preserving the historical record of this country.

We do have some questions about plans for implementing this collection. The project seems to be predicated upon a substantial investment from the library community, but does not contain any evidence that this support is forthcoming. Is GPO stating that their vision is to take a leadership role in developing partnerships and other financial support to fully implement this plan? A cost analysis that includes some committed partners is needed in the proposal, along with fuller explanation of the documentation provided, such as the number of titles to be digitized within the 3-5 year time frame for assembling the CLR.

We note that the June 18, 2004 revision of the CLR specified plans for use of multiple collections located at multiple sites, an especially important feature of this proposal. Active participation by depository libraries is essential to ensure the preservation of this enormous collection, and the depository library community stands ready to assist in these preservation efforts. However, a plan for the geographical distribution and management of this collection is lacking, and we encourage its inclusion in the final document.

A major concern of the depository library community is the loss of born digital materials.

While preservation of the legacy print collection is extremely important, it should not be accomplished at the expense of capturing born digital publications, which are disappearing at an unknown rate. The loss of these materials is a major concern of the depository library community, and we feel the CLR must place more emphasis than has been expended to date on acquiring and preserving these publications. We agree wholeheartedly with the plan to make tangible copies of these and preserve them within a dark archive; however, the proposal lacks a clear articulation of plans to work with agencies in obtaining publications, rather than relying upon voluntary agency participation. While we commend the recent agreement between GPO and the OMB as an important first step, we are alarmed at the amount of material that has already been lost, and are concerned that not enough attention is being paid to this aspect of government information dissemination. GODORT recommends that GPO clearly states in the CLR its commitment to a policy that preserves born digital documents and its recognition of the priority of this issue.

Another question that is not well addressed in this document is how to preserve born digital media that are not in a linear format. Databases and other resources in which user interaction and manipulation of the information is an essential quality cannot be usefully rendered in print. These materials must be archived in a manner that preserves their usefulness. We encourage GPO to keep abreast of ongoing research in this area of digital preservation, so as to incorporate developments into its preservation plan.

One area not addressed in the planning document is the question of what happens to those citizens who do not have Internet access. While access to the Internet is growing, it is not now and never will be available from 100% of all households. This is an area in which GPO should strengthen its partnership with federal depository libraries. GPO should identify underserved communities and adopt a proactive role in recruiting area libraries to provide access to government information. This could include help with funding equipment, or if the community has no Internet access at all, offering the library extensive print-on-demand to be used to satisfy the needs of that library’s constituents.

Generally it is believed that digitizing information and making it available through the web improves public access. This is only true if the information can be found at the point of need. GPO should take care to make the collection available from a variety of access points. This would include but not be limited to creating records and links that are compatible with highly used databases. Bibliographic records should be in MARC format and conform to OCLC and LC standards. Links should be open-URL compatible and should be offered at title, issue and article level. GPO should run usability studies to discover best practices to support novice searchers in their information needs. Further, GPO should offer training to information professionals who work directly with the public so that they may provide public assistance in locating needed government information.

The development of a Collection of Last Resort will fill a long-standing priority for the depository library community for a reliable preservation mechanism. We look forward to the final proposal, and continuing collaboration between the depository libraries and GPO to accomplish this project.


Sincerely,

John A. Stevenson

Chair, Government Documents Round Table

Coordinator, Government Documents and Maps Processing Unit

University of Delaware Library

181 S. College Ave.

Newark, DE 19717-5267