The Federal Depository Library Council believes this report is a reasonable initial public draft for an assurance and decision framework for developing a system of regional repositories for tangible federal government documents. As Council understands from this draft and other planning discussions, the tangible federal government document system would tentatively be based on two dark archives (highest assurance level), a larger number of "light archives," and designated depository libraries (lowest assurance level). Council generally supports this proposed configuration of dark and light archives as a reasonable strategy for providing preservation of the tangible FDLP collection, and as a backup for operational depository library collections.

Council includes several suggestions and questions below that we recommend be clarified in the final version.

In general, the "low" end of assurance is not adequate for any sort of archival facility. The low end is much more indicative of the current environment in many depository libraries. However, in the criteria for accessibility the "low" level of assurance (gov docs do not circulate) actually gives a higher level of confidence in the archival nature of the repository than the "high" level of assurance (unrestricted circulation). This confusion should probably be cleared up.

Cataloging/metadata Production - Every depository library is required to comply with the highest level of assurance (piece level holdings). It seems that the low level of assurance for this category - published GPO catalogs only - is setting the bar too low.

Seems to assume a SuDoc arrangement of the repository. See under "Storage and Integration" that this might not be the ideal arrangement for an archival collection.

The term "off-site" seems to assume that there is no public access at the storage facility itself. Many archival facilities make some provision for public reading space. A high assurance level might be "stored off-site and available only in surrogate copy."

An RFID tag might not represent the highest level of assurance for an archival system which is designed to withstand a nuclear attack or other massive catastrophe.

Would there be on-site users in the dark archive?

As stated above it appears that the high through low rankings are reversed in this section, by definition archival facilities restrict access to originals, whether on site, or via circulation or ILL. It should be made clear that a good archival repository should have a "low" assurance level on some of these measures.

On site - The inclusion of the "medium" level – restricting who has access – is unacceptable since we are dealing with public information. Would any access be available, even by appointment, for use of dark archive materials?

Is state or federal funding and governance necessarily more stable than well established, well funded private institution or university.