Testimony Submitted for the Record

On Behalf of the American Library Association regarding the Library of Congress Oversight Hearing Before the Committee on House Administration
July 27, 2006
Submitted by Lynne E. Bradley, Director, ALA Office of Government Relations, Washington Office, 1615 New Hampshire Ave., NW, Washington, D.C. 20009, 202-628-8410

On behalf of the over 66,000 members of the American Library Association (ALA), we commend the Committee on House Administration for scheduling its July 27, 2006, oversight hearing on the Library of Congress (“the Library”). This is a critical time to review the continuing technology, design and preservation initiatives at the Library.

While the Library’s first function is to serve Congress, it also serves as a de-facto “national library” that has a substantial economic impact on libraries of all types across this country. The Library’s tremendous collections, preservation projects, cataloguing and bibliographic functions, and, more recently, its digital initiatives make the Library a world-class resource upon which all libraries rely in some fashion. ALA applauds these services and initiatives and seeks to continue and preserve the collaborative working relationship the library community has with the Library.

As the largest and oldest library association in the world, ALA appreciates the complexities faced by any institution with limited resources as it makes decisions about digitization of materials and how best to manage evolving technologies’ potential for new and innovative functions and capabilities. As our nation’s libraries, including the Library of Congress, seek to move ever deeper into the digital world, there are many hard decisions to be made. At the Library, these decisions have a special impact on all types of libraries and library users. The Library cannot and should not move forward in a vacuum.

The Library’s role in cataloguing and classifying the nation’s library materials is especially important. It has occupied a leadership position in the development of standards of practice for bibliographic access to library materials for more than a century. Library of Congress cataloguing records comprise the largest single body of bibliographic records shared by libraries across the nation. These records provide the means by which any library - whether it is a public library, school library, college or university library, museum library, or any other library -- is able to provide users with adequate access to its collections.

The cataloguing performed by the Library and made available to the nation’s libraries is one of the most critical national functions of the Library of Congress. A substantial part of the Library’s funding by Congress is to enable them to perform these functions on behalf of the nation’s libraries, of which there are a number in every Congressional district. ALA’s support for such funding has been strong and long standing, but that support has been with the understanding that the Library will fulfill the role for which it is funded.

Any diminution of the quality or quantity of cataloging provided by the Library of Congress has an enormous financial impact on all of the nation’s libraries, because the missing quantity or quality of cataloguing data must either be redressed by individual libraries, often doing work in duplicate, or it must be abandoned altogether. Any cuts to the quality or quantity of cataloging provided by the Library also has an enormous impact on the users of the nation’s libraries - from the youngest child to the oldest man or woman, from the recreational reader to the most serious researcher - in terms of diminished ability to locate and identify desired information.

Because of the great importance of these matters, ALA was prompted in May of this year to write the Library regarding its decision to cease the creation of series authority records and treating all series only via transcription in bibliographic records. ALA is concerned not only about the direct impact on libraries and their users of this specific cutback, but also on the process and dynamics surrounding the decision. At the same time as the policy regarding series authority control was being prepared, announced, and discussed, officials at the Library of Congress were indicating publicly that the Library is actively considering alteration of other cataloguing practices, such as abandonment or radical alteration of application of the Library of Congress Subject Headings. These changes would also have a catastrophic financial impact on the nation’s libraries and their users and have been greeted with concern not only from the library community, but also from library users.

Our understanding of the background of the recent incident is as follows: On April 20, 2006, the Library of Congress announced that as of May 1, 2006, it would cease performing series authority work for the bibliographic records it creates. The announcement was greeted with dismay in the library community, in part because of the substance of the decision; in part because of the shortness of notice given; and in part because the decision was reached without sufficient consultation with the broad library community.

As a result of this response and to enable libraries to plan their operational response to the Library’s new practice, the Library of Congress delayed implementation of the change until June 1, 2006. Although an avenue for comment was provided in the announcement of the delay, it appeared that there was no intent to consider modification of the decision based on comments received. While the delay was welcomed, forty days still allowed far too little time for libraries to understand the full implications of the decision, to assess their options, and to make adequate plans for how or whether they will continue to provide authority control for any or all series in their own catalogs.

For example, the Program for Cooperative Cataloguing Libraries (PCC) could decide to continue doing series authority work and take on the role of maintaining a national/international series authority file. However, this will mean many more hours of work for that dedicated group, to create Series Authority Records and to update Library of Congress bibliographic records that they previously did not need to touch. Because the PCC is mainly composed of academic libraries, we are most concerned about children’s and popular materials.

Many children’s materials are issued in series, and collocating these materials in a consistent manner through established series forms is crucial to maintaining good public access to materials in public libraries. In addition, the work of collection development and acquisitions personnel will be made more difficult, as it will no longer be possible to collocate books in one given series; unless much more effort is taken in searching the catalog, duplicate orders and gaps in holdings are to be expected.

Controlled access to series information is one example of the important ways by which libraries and library users discover information or make it available to others. Keyword search is not an adequate substitute for authority-controlled series access, especially over time as variants and name changes proliferate, and as errors enter even the best databases.

We hope that the Library understands the impact that its decisions have on other libraries. Library of Congress bibliographic records are accepted without editing by thousands of libraries of all types and sizes throughout the world for use in their own online catalogues. Libraries accepting unedited Library of Congress copy will now lose controlled series access in their catalogs. If they elect to take on this task themselves, it will mean a great deal of labor intensive checking and editing of records -- labor that was not previously needed.

The American Library Association is also concerned about the manner in which the series authority decision was reached and announced, without sufficient opportunity for the broad library and cataloging community to discuss the impact of the decision, or to suggest modifications to it that would lessen its negative impact. ALA asks the Committee to require the Library of Congress to consult broadly with the library community, including organizations central to bibliographic control, regarding any future decisions to substantively modify the content of bibliographic records, and to take into account in reaching its decisions, the potential financial impact on all types of libraries, and the impact on access to library materials by all types of library users.

For example, if consultation with affected communities had been undertaken prior to announcing a final decision on the series authority issue (as had been done historically,) it is possible that a compromise or simplification of series authority creation could have been mutually agreed upon in the library community. Also, broad consultation of the sort described would provide a means for the Library to understand better both the costs and benefits.

It appears that the importance of Library of Congress cataloging to the nation’s libraries and to the development of an educated and informed populace is not sufficiently appreciated by the Library’s senior administration. The library community has come to expect, and appreciate, both significant lead time for implementation of policy changes of this magnitude and widespread communication with multiple and even international constituencies. Such consultation with the library community has been the model used in the past by the Library.

ALA believes it is imperative that there be a meeting or series of discussions of representatives of the Library of Congress, the ALA, and other interested bodies such as the Program for Cooperative Cataloging, OCLC, the Association of Research Libraries, the National Libraries of Agriculture and Medicine, and the Government Printing Office, for the purpose of discussions of the future shared responsibilities and roles of these bodies in leadership and standards development for bibliographic control and intellectual access, and in the creation and provision of quality bibliographic records. We are aware that the Library has recently started to organize a similar group to plan a summit or other venue to discuss the future of cataloguing, although it is unclear whether the Library is willing to postpone and adapt its long-term plans regarding cutbacks and readjustments to cataloguing services, especially related to subject cataloguing, based upon the input from such a summit or set of meetings. We would also hope that the participants in such a group have broader representation as we have suggested in this testimony.

ALA urges the Committee on House Administration to continue its oversight functions of the Library and to require the Library to delay its implementation of future cutbacks in its bibliographic records functions so that there is sufficient time to enable informed response from the library community, including from organizations central to bibliographic control such as the American Library Association, the Program for Cooperative Cataloging, and OCLC.

The American Library Association requests that the Library of Congress return to its former practice of broad consultation prior to making significant changes in cataloging policy. It is understood that, despite the opinions of those who may believe that library cataloging has become fixed at some indeterminate moment in the past, in fact both policies and practices are in constant states of change and development. Nevertheless, unilateral and sudden actions on the part of leading agencies are likely to result in further fragmentation of the community. ALA specifically requests that the Library establish a 90-day comment period before implementation of future changes, so that the varied members of our community can make themselves heard, not only by the Library itself, but also by each other, in a considered and coherent manner.

Further, we urge the Library’s leadership to re-dedicate itself to cooperative cataloging programs and cooperative standards efforts, in which both the Library of Congress and partner libraries can benefit from standards established together. All partners benefit from sharing standards and training; the result is a more effective and efficient copy cataloguing process for all partners when accepting copy from trusted sources. ALA and others in the library community stand ready to work with the Library and with the Committee on House Administration on this important effort. Such consultation and collaboration can help assure that the Library of Congress will truly be a Library of the 21st Century.