Homedecframefinal

July 29, 2004

Judith C. Russell

Managing Director, Information Dissemination (Superintendent of Documents)

U.S. Government Printing Office

Washington, DC 20401

Dear Ms. Russell:

Thank you for posting the Decision Framework for Federal Document Repositories discussion draft. The Government Documents Round Table (GODORT) of the American Library Association (ALA) applauds the willingness of the Government Printing Office to seek information and opinion from its partners. Noting that many suggestions and questions are included in “Depository Library Council’s Comments on the Draft Decision Framework for Federal Document Repositories” dated May 13, 2004, GODORT offers some additional comments on the discussion draft.

GODORT feels that it would be helpful to have a Government Printing Office (GPO) authored introduction to the Decision Framework for Federal Document Repositories draft. GPO could use its introduction to explain details such as why the GPO chose the Center for Research Libraries to design this framework and how GPO expects to use this framework once it is finalized.

The working definition of the Dark archive in the decision framework raises concerns in some readers with the concept of eventually “lighting” the archive. If the point of the dark archive is to safeguard originals that can be used in the future to re-create masters for printing or digitization, are we to understand that the dark archive would only be opened to retrieve individual items when copies from the light archive prove unusable? The working definition speaks of ‘“lighting” the archives’ but if the action being described is retrieval of individual titles “triggered by a specified event or condition” it would be better to say so. Would retrieved titles be returned to the dark archive following use so as to preserve the dark archive collection?

In the introduction to the matrices, the Center for Research Libraries (CRL) postulates ‘at least one “dark” or secure archive.’ In Part 3 of the document it becomes clear that a single dark archive offers a very low assurance level. The desirability of multiple dark archives should be made clearer in the introduction to the document.

Comments on the Matrices: Format

The designation of “high” and “low” is confusing when presented without sufficient context. It looks as if, at times, even the authors of the document became confused. In almost all cases the “high” and “low” designations refer to the measure listed immediately above the factors. For instance, “Access to Originals - local circulation” rates “Government Documents do not circulate” as “low” and “Unrestricted circulation” as “high.” However, in at least one case, the “low” and “high” seem to be inverted. Under “Integration of Government Publication Collections” “low” indicates that government documents are integrated with other library collections, while “high” indicates that they are kept separate.

It is easy to lose track within the decision matrix. It might clarify matters if, within each section, the appropriateness of “high” or “low” assurance levels would be indicated for different types of archives. One sentence could follow each measure indicating the optimal situation (“high”, “low”, or “high” for dark archives, “low” for light archives, etc.).

Comments on the Matrices: Substance

Some of the factors listed under the measures need further discussion.

In this document, the use of the term “security” seems to be limited to measures to prevent the theft of materials. While the description of materials retrieved from closed stacks may imply greater security, it may be important to note that archives and rare book reading rooms usually guard against patrons destroying or defacing materials in addition to guarding against theft. To assure preservation of originals, it is standard practice for archives to require patrons to leave all tools that could leave a permanent mark on documents outside. Most archives also have staff monitor reading rooms as a defense against mutilation of documents. Common higher security measures used by libraries are not mentioned in the portion of the document that discusses security.

Current capacity and growth potential seem to be based on extrapolating from current receipts for 10-15 years into the future but does not take into account the potential increase in volume if the proposed Collection of Last Resort includes documents printed from electronic originals. What is the basis for the assumptions about growth rates? It would be helpful to have this explained in the decision framework.

Levels of assistance (both on-site and remote) are based on service desk location and a dedicated phone line. Are these really the appropriate measures? Shouldn’t staffing levels and training be considered? Further on, when levels of staffing are mentioned they are not linked to constituent base or to the number of questions expected. Aren’t there situations in which one government documents trained librarian is not sufficient and should not be considered a “high” level of staffing?

“Repository Governance and Funding” ranks private institutions “low” and federally funded institutions “high.” Clarification on what is being measured would be helpful. If the ranking measures the level of reliance on the federal government, it should be explicitly stated.

Although this Decision Framework for Federal Document Repositories discussion draft leaves many questions unanswered, the creation of this draft represents an important step. GODORT looks forward to participating in future discussions with GPO to develop the decision framework for Federal Document Repositories.

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