F e d e r a l    D e p o s i t o r y    L i b r a r y    P r o g r a m

Council commends the Public Printer and the Managing Director of Information Dissemination/Superintendent of Documents for their leadership roles on this very important issue.

With regard to selection for the legacy collection project, we recognize that there is an interest among library directors in identifying long runs of titles for which there is broad interest in the research community, occupy large amounts of shelf-space, and may be expensive to acquire in digital form from commercial vendors.

Council is deeply concerned that the targets for digital preservation should include some evaluation of the print documents most at-risk of loss. Council suggests that GPO engage in a preservation assessment of both microform and print publications with emphasis on 20th to early 21st century materials. Further, Council encourages GPO to partner with the depository library community, the National Archives and Records Administration and other federal agencies in the pursuit of this effort. Print publications on onion-skin and other poor-quality paper should be given a high priority for the project. Microfiche titles that may have print equivalents available are also an appropriate early target for the legacy project.

The intellectual content of the legacy collection is also a concern to the depository community. Council recommends GPO for soliciting input from those with subject expertise, including, for example, members of GODORT’s Rare and Endangered Government Publications Committee.

Council further recommends that flexibility be affirmed as part of the GPO’s retrospective digitization strategy. The report’s language on page 5, paragraph 3 acknowledges that some experts "expressed concern the GPO not set a bar so high that it would exclude smaller institutions from making contributions that they may be in a unique position to make." While the GPO benchmark for the creation of digital preservation masters is based appropriately on the recommendations of digital preservation specialists, a dynamic program with maximum feasible participation should allow creation of digital access copies with a benchmark that is less rigorous. Many libraries have already completed, or initiated, projects in which the digital preservation master standard cannot be met. It does not seem reasonable to exclude the contribution of this content to the Legacy Collection. Council urges GPO to survey the depository community and evaluate the suitability of these projects for inclusion in the Legacy Collection. It is Council's belief that many of these projects would be worth inclusion thus allowing GPO to concentrate its efforts on other aspects of the Legacy Collection.

Council believes it to be unreasonable to make the creation of the preservation master according to current standards a prerequisite for participation. While Council strongly supports a preservation master as the best means by which to achieve permanent public access, libraries that have created access copies without a preservation master should not be denied participation and GPO might wish to devote its expertise and appropriate resources to the creation of a preservation master in this scenario. At the local level each library may view a particular aspect of their collection as the best starting point for access. GPO should not deny that library the ability to participate simply because a preservation master wasn't developed in accordance to current stands; rather GPO might wish to create the preservation master itself.

In addition, Council suggests that GPO note that technologies, standards and best practices in all areas are evolving. Council suggests that libraries who chose to create digital access copies (without a correlate preservation master) may be allowed to use cheaper and more efficient technology in the future to create high-quality preservation masters in a more expedient yet less costly manner than current technologies provide. Council strongly recommends that the same level of engagement for creating preservation-quality digital masters for retrospective material be applied to the establishment of preservation standards for born-digital content. A similar expert meeting should be convened that addresses issues related to the capture, processing, storage, and preservation of born digital content including tangible and non-tangible formats, databases, and dynamic pages (information generated on-the-fly).