From jrussell@gpo.govTue Mar 26 17:13:34 1996 Date: Mon, 25 Mar 1996 23:02:19 -0600 From: "Judith C. Russell" Reply to: Discussion of Government Document Issues To: Multiple recipients of list GOVDOC-L Subject: FDLP Study: Draft Report Section 5: Policy Issues DRAFT REPORT FOR THE STUDY TO IDENTIFY MEASURES NECESSARY FOR A SUCCESSFUL TRANSITION TO A MORE ELECTRONIC FEDERAL DEPOSITORY LIBRARY PROGRAM (FDLP) SECTION V. Policy Issues That Impact Publishing Agencies, GPO, NARA, Depository Libraries, the Public, and the Private Sector GPO is now compiling the final report for the FDLP study. Included below is the draft of section V. Other sections of the report will be released individually as soon as they are completed. Although time is short, your comments are welcome. You can send Internet e-mail to study@gpo.gov or send a fax to the attention of FDLP Study at 202-512-1262. Correspondence can be addressed to FDLP Study, Mail Stop SDE, U.S. Government Printing Office, Washington, DC 20401. ***************************************************************** V. Policy Issues That Impact Publishing Agencies, GPO, NARA, Depository Libraries, the Public, and the Private Sector The issues summarized below were identified during the course of the study. Many of them are explained in greater detail, with examples and alternative solutions, in the individual Task Force Reports that are included as Attachments E-1 to E-14. ISSUE 1. REDEFINITION OF TERMS; AUTHENTICITY OF INFORMATION The electronic publishing environment necessitates new definitions of terms such as Government Publication, Government Information Product, and Government Information Service as well as new means to identify, and assure the authenticity of electronic Government information. A. The scope of Government information included in the FDLP and the criteria for excluding information from the FDLP must be established through revision of 44 USC 1901 and 1902. These sections must explicitly include all formats of Government information, including electronic information. Since NARA accepts dissemination through the FDLP as one criteria for identifying information for permanent preservation, this will also serve to define a body of electronic Government information that will be transferred by GPO to NARA for preservation. B. Means must be found to assure the authenticity of Government information in the FDLP, both for the current users and usage and for permanent access and preservation. This may include the utilization of "signatures" on electronic Government information products (files) and the establishment of a unique and permanent name or identification number for each file that is constant throughout its life-cycle. Authentication efforts should assure the accuracy of the information content without imposing barriers to reuse. ISSUE 2. CHANGING ROLES FOR FDLP PARTICIPANTS The focus of the FDLP is changing, so that GPO is providing more access and less dissemination and depository libraries are providing connections to remote information sources, rather than building collections in their own facility. A. The role of GPO as the agency responsible for administration of the FDLP must be redefined to include the authority to establish official arrangements for depository library access to information available directly from Federal agencies or other organizations, with the appropriate provisions for permanent access to and through the FDLP. This will assure that GPO, and the depository libraries, can rely on access through these distributed sources, rather than collecting the information for a single, central computer system operated by GPO or requiring the libraries to maintain extensive local collections of electronic Government information. B. The role of depository libraries must be redefined to include requirements to serve as local providers of public access workstations and the related services necessary to connect the public to remote Government information. This redefinition will result in different types of resource and training requirements that the libraries must meet in order to assure equitable access to Government information. C. Means must be found to assure that publishing agencies in all branches of the Federal Government are responsible for, and do provide, notification to GPO as the administrator of the FDLP and to other affected parties before they create new Government information products, or significantly change or eliminate existing information products. This includes notification of removal, or change of address, of information on an agency Web site when availability on that site is the means by which the agency fulfills its depository responsibilities. The Paperwork Reduction Act establishes a notification requirement for publishing agencies in the Executive branch, but it does not explicitly identify GPO, and the FDLP, as one of the entities that must be notified. There is no comparable statutory requirement for Legislative and Judicial branch publishers. It is not enough to establish the obligation, there must be means to assure compliance if the FDLP and others are to rely on this notification. ISSUE 3: PERMANENT ACCESS AND PRESERVATION The requirements for permanent access to and preservation of electronic Government information necessitate a re-evaluation of the life cycle of that information. The best time to assure preservation of official electronic Government information is usually at the time it is prepared, when the originator can certify its authenticity. A. NARA and GPO must establish an official relationship to assure that electronic Government information disseminated to depository libraries by GPO, or held by GPO for depository library access, is transferred to NARA for preservation in formats acceptable to NARA. Ideally, this should be done in a manner that meets the publishing agencies' requirements for deposit with NARA, so that duplicative preparation and transfer of such information is eliminated. B. The requirement for permanent public access at or through depostiory libraries necessitates (1) the creation of information in formats that resist technological obsolescence due to software or platform dependence; and/or (2) periodic review and refreshing of data to minimize deterioration and assure technological currency throughout its life cycle. ISSUE 4: STANDARDS The requirements for timely access to current Government information within the scope of the FDLP and for permanent access to and preservation of that information necessitate the development and implementation of standards for formatting electronic Government information. A. Broad utilization of Standard Generalized Markup Language (SGML) in the preparation of Government information will facilitate the exchange, dissemination and preservation of that information; however, it will take many years for this to be broadly accepted throughout the Government. B. As the agency responsible for the administration of the FDLP, GPO will need to establish a range of preferred file formats, including SGML, for use in the FDLP and to recommend (but not require) publishing agencies to use one of those formats when submitting electronic Government information to GPO for FDLP dissemination. Whenever possible, open systems and formats compliant with Federal Information Processing Standards (FIPS) and other national or international standards will be used to assure that the format of the information is not a barrier to its use. Such standardization is essential to assure that depository libraries have the hardware, software and training necessary to assist the public in the utilization of information made available through the FDLP. C. When agencies cannot, or do not, use one of the preferred formats, GPO will need the authority and the funding to convert agency supplied electronic Government information to one of the preferred formats if that is necessary to assure that the information is appropriate to the needs of users and intended usage. The formats selected for FDLP dissemination must be appropriate for the program's intended audience, representing a broad cross section of the general public. If the format selected by the publishing agency is not suitable for public access through the FDLP, GPO should convert, repackage or scan the information product for distribution through the FDLP. This will not restrict dissemination by Federal agencies in the formats which they feel best serve the needs of their primary constituencies, but rather will supplement agency dissemination efforts by assuring availability to a wider range of users through the FDLP. D. Where paper and microfiche are formats that do not face technological obsolescence, many electronic information formats are software or platform dependent, necessitating the periodic review and, when necessary, refreshing of that information to newer media and or file formats. Creation in, and certification of, information in standard formats that are not technologically dependent is the best way to assure that Government information is preserved and remains permanently accessible. E. The use of standards in the preparation and dissemination of Government information will also facilitate its incorporation in value-added information products from the private sector and assure a diversity of sources for Government information. ISSUE 5. LOCATOR SERVICES With the proliferation of Government electronic information services, and the necessity to link or direct depository libraries to those services, rather than duplicating them, the provision of comprehensive finding aids and indexing (locator) services is essential. This includes full participation in and utilization of the Government Information Locator Service (GILS) as well as development of other locator services tailored specifically to the needs of the FDLP. ISSUE 6. INCLUSION OF FEE-BASED SERVICES IN THE FDLP The principles for Government information, and many of the laws and policies implementing them, recognize the need for assuring broad public access to Government information. The statute authorizing the FDLP specifically requires no-fee public access; however, this requirement is often in conflict with statutes establishing fee-based Government information services. Providing GPO with the authority, and funds, to purchase access to fee-based Government information services is one means to reduce this conflict. Implementation of such authority would require the establishment of a basis for determining appropriate fees for depository access and the restrictions, in any, that such services should be able to place on the use and reuse of information provided to the public through the FDLP. ISSUE 7. AVOIDANCE OF COPYRIGHT-LIKE RESTRICTIONS Government information must be available without copyright-like restrictions to assure broad public access and a diversity of sources. When publishing agencies impose, or permit others to impose, copyright-like restrictions on information created or compiled by Government employees or at Government expense, the effect is to restrict public access to that information. This violates the intent, if not the specific provisions, of the laws and policies precluding copyright on Federal information, including the Paperwork Reduction Act and OMB Circular A-130. Nevertheless, budget constraints, requirements for operating cost-recovery information services, and other factors are encouraging agencies to treat Government information as a commodity whose economic value can only be preserved by the imposition of such restrictions. Excessive fees, exclusive arrangements, charging royalties, and placing restriction on use or reuse of Government information are examples of copyright-like restrictions that must not be permitted. The utilization of proprietary formats may also impose copyright-like restrictions by requiring users to obtain software licenses in order to access the information. ISSUE 8. INCENTIVES FOR AGENCY COMPLIANCE WITH FDLP REQUIREMENTS As the agency responsible for the administration of the FDLP, GPO must inform publishing agencies of their obligations to the program. The Office of Management and Budget (OMB) and the Congress can, and should, assist GPO in making sure that agencies understand the requirements for participation in the FDLP and comply with them. GPO must have the ability to offer incentives for participation and to assure publishing agency compliance with statutory obligations to the FDLP. ***************************************************************** Individuals and organizations wishing to provide comments can send Internet e-mail to study@gpo.gov or send a fax to the attention of FDLP Study at 202-512-1262. Correspondence can be addressed to FDLP Study, Mail Stop SDE, U.S. Government Printing Office, Washington, DC 20401.