The Federal Depository Library Program is almost two centuries old. Most librarians would agree that this system has provided this country with very effective access to Government publications and Government information during the last 200 years. However, the electronic revolution has raised many issues about the future of the program in general and, in particular, about the value of participation in the program.

It is almost impossible to grasp the full magnitude of what is happening. Let me cite one eye-catching statistic. In October 1995, about 800,000 documents were downloaded from GPO Access. In March 2000, 29.1 million documents were downloaded from GPO Access. That is in just one month. That is a 30-fold increase in just five years. I understand that the monthly average is currently 26 million documents. That is close to 300 million documents a year. It is mind-boggling.

How does this incredible electronic achievement affect the traditional depository program? As Government information has become increasingly available on the Web, many library administrators have questioned the costs and benefits of continuing to participate in the program. What is the relevance of continuing to receive millions of documents in print and continuing to spend very substantial library resources on the processing and management of these resources? Those are the questions we want to grapple with today. For those of you who are considering whether to retain your depository status, we would like to present you with some of the considerations you may wish to take into account in making this decision.

Let me explain the format we have decided to use. Instead of having members of the panel address you sequentially, we have decided to use a question and answer format. I will present questions to the panel and ask members to take turns providing their perspectives on the questions. We have grouped the questions into several categories. Your handout includes the questions and you might want to follow the questions on your handout as we move along.

Before we begin the discussion, I would like to introduce the speakers on our panel. All the speakers on the panel bring a lot of expertise to the issues we are considering in this program. I am very excited they have agreed to come today to share their experience and insights.

Let me start with Sheila McGarr. Since June 1999, Sheila has been the Chief of the Library Division at the Library Programs Service at GPO. Prior to 1999, Sheila held a number of positions at GPO involving the FDLP, including Chief of Depository Services and Chief of the Depository Administration Branch. She continues to supervise the depository library inspectors. Sheila received her MSLS from Catholic University and her BA from Merrimack College.

David Heisser is Reference and Documents Librarian at the Daniel Library of The Citadel Military College in Charleston, South Carolina, where he has worked since 1995. He has a MLS from Columbia University. He has been a documents librarian for most of the past 23 years and is currently Federal Relations Coordinator of the South Carolina Library Association. Last year David published an article in Government Information Quarterly about depository library administrators' plans for offering public services in the age of electronic transformation of Government information. This is listed in your bibliography.

Betsy McKenzie has been a law librarian since 1986 and Director of Suffolk University Law Library since 1996. Several years ago, Suffolk decided to drop its depository status. Betsy was the Director of the library when this decision was undertaken. I think we are fortunate to have Betsy here to share some of the considerations and issues that were involved in this decision.

I would like to mention, in particular, two aspects of Betsy’s experience that are relevant to the program we are presenting today. First, as a graduate student in library science at the University of Kentucky, Betsy had a graduate assistantship in government documents. This experience was very influential in the development of Betsy’s views concerning some of the issues we will discuss today. The second experience occurred while Betsy was serving as Chair of Legal Information Services to the Public Special Interest section of the American Association of Law Libraries several years ago. At that time, Greta Boeringer approached Betsy about co-sponsoring several programs concerning Federal depository issues. Greta is a former FDLP library inspector and has strong views about the obligations that depository libraries have to the public. At that time, Betsy and Greta had a number of conversations that had an important impact on Betsy’s views when it came time to consider Suffolk’s depository status.

Let me note that we have prepared a bibliography. You can find extensive discussions of the questions we will address today in the articles and materials cited in the bibliography. There is also a list of the questions I will pose to the speakers during the program, which you have, as a handout.

Sheila’s point about the age of the depository is particularly good in this section. If we had become a depository in earlier years, or held rare materials for some other reason, we would have been much more likely to lose valued items upon leaving the depository system. The materials would also have been more difficult to replace.

I also liked the comments made about electronic materials. Some materials are just not suitable in electronic format, at least until electronic paper makes lengthy reading of electronic documents comfortable.

I am very worried about the continued availability of electronic materials from the GPO and especially agency sources. Even if the materials are archived, which does not seem to be happening yet, the archiving institution must commit to updating the format as technology advances. Those of us with 5.25 inch disks or files in Wordstar format will understand the need to copy electronic documents periodically into the current format in order to ensure continued access over time.

I can't underscore too strongly the great issue of archiving of the information. Some of the value of the individual depositories will be to archive hard copy documents. And the program as a whole should help to direct the archiving of electronic documents. I would hope libraries would think hard about making a contribution to that effort.

The bibliography lists several excellent studies looking at the total cost to a library of participating in the depository program. These include such hidden costs as the need for more highly trained personnel for acquisitions, processing, and reference services dealing with government documents. There are the costs of complying with special FDLP requirements such as time on the Needs and Offers lists before discarding unwanted material, or dedicating new electronic equipment to depository patron use. There is the more indirect expense of constantly receiving unwanted documents because one must select the entire item number and accept everything that is grouped there. Ironically, the more serious the library is about providing real access to documents, the more expensive participating in the FDLP becomes.

The expense of maintaining a good depository library is higher than many have thought. Libraries are not receiving strictly "free" materials through the Federal Depository Library Program. There are extra finding aids, such as Andriot's or SilverPlatter to buy, as well as the hidden expenses mentioned above. With the migration of so much government material to the Web, the benefit of participating in the depository program is shrinking for those libraries where the mission does not include public access as a central value. Not everything is on the Web, or ever will be. But the more is there, the less reason may appear to continue in the FDLP. Note my concern about archiving and long-term access to this material. However, those materials that are marginal to my collection are tempting to get from the Web now and count on other libraries to warehouse it for later needs.

The costs of withdrawing from FDLP must also be weighed. We must replace through paid subscriptions the serial items we wish to continue receiving. Because of difficulties in ordering through the government, our library decided to pay extra and use a jobber to replace most government documents. For exact information on the added expense, see the article I co-authored, which is listed in the bibliography. A library that is required to return materials to the Regional depository must also spend money to replace (if possible) those materials. There are other, unquantifiable costs to consider as well. We lose the expertise of the documents librarian. Depending on the community, we may lose the status of participating in the FDLP, and the good will generated from supplying documents to the larger community. Some libraries lose the ability to point to FDLP standards and requirements to pressure parent institutions or communities into funding these purchases.

We did not save any money by withdrawing from the program, even considering the personnel costs and other indirect costs to our libraries. We did not eliminate any positions. Our former government documents librarian position was vacated and transformed into a regular reference librarian. Our former documents processor moved to another position in the library, and we replaced his position with a serials clerk. The serials clerk was needed because that department carried the long-term brunt of processing the materials we now receive from our jobber that formerly came from GPO. Although these replacement positions are not as highly paid, we spent the savings and more on vendors. We pay for the items we receive now, and even something extra for the convenience of using a jobber. Although we only receive items that we really want, and do not have the FDLP standards and special requirements, leaving the FDLP was not a cost saving to us at all. I should say here that we left the program, not because of cost considerations, but because we were informed that the new building would require ID cards to access the front door and again to open the elevators on the library floor. We considered that this aspect of our new building would make it impossible to truly comply with the obligation to allow public access on an equal footing with our regular patrons. I feel strongly that, having accepted the benefit of the depository program materials for my library, we have a reciprocal obligation to supply access to those materials to the public.

Being a depository entails investing in public workstations and other equipment that may be costly to acquire and maintain in accordance with GPO standards. But I have heard from many colleagues that, instead of being an intolerable burden, the standards have helped the library to justify purchases of high end equipment that will also be used for other services--in other words, the standards have helped them obtain things they were eventually going to need anyway.

When it comes to public service, documents librarians have always been zealots. The phrase "Documents to the People" is not just a slogan. It is a battle cry. Maintaining collections of documents in paper and other formats has always entailed a strong service commitment.

So, if a library considers leaving the depository program, it should look carefully at its mission. My institution is a state college, so we'll offer public access and service no matter what happens. And I have heard library directors at private academic institutions speak eloquently of their schools' ongoing commitment to serving the general public of their communities.

In 1998, I visited 24 depository libraries, 8 each in three regions of the country, and I interviewed the library directors and documents librarians about how they expected to provide public service in an electronic environment. These institutions included public libraries and both private and public colleges and universities. I was impressed by the strong commitment so many expressed to continuing to offer service to the public. At some of the private academic libraries I was told that their parent institutions had a policy of being a beneficial part of their communities, and that depository service was part of this. I found such strong positive statements that I suspected that, if the depository program died, it would be a matter of the ship leaving the rats. In recent weeks I have been back in contact with people at the institutions I visited in '98. And although several of these have conducted or will conduct reviews of the benefits of staying with the program, I am still hearing a willingness to offer some degree of public service.

But libraries are finding themselves compelled by their institutions to measure and justify the benefits and costs of remaining in the program and providing service to a public outside their primary clientele, usually meaning their tuition-paying students. A number of prestigious private academic institutions in different parts of the country are watching the changing situation very closely.

As a matter of interest I'd like to ask--would you raise your hand, if you work in a library where, if you were not in the depository program, your institution would probably curtail or deny general public access?

In the paper environment there was a kind of social contract whereby the library agreed to serve the general public in return for the valuable and hard-to-get documents. But the deal may not look so appealing if most documents are made available to all on the Web. Of course, having information on the Web doesn't mean that people don't need assistance in finding and using that information--or even in gaining access to the Web itself. There are still many people who are not computer-literate. The Internet may well increase the public's expectations for information and for service.

If your library is thinking of getting out of the program, I would urge you to gauge the impact this will have on all your users, present and future. And try to assess the effects on your surrounding community. Will you continue to assist the public? If you restrict access and service, where can people turn for help? I think it is also worth considering what community you serve--now that the Web and e-mail obliterate geographic and political boundaries, Congressional districts and even state lines.

You may consider what impact your withdrawal will have on the depository program itself and its ability to serve the public. As a documents librarian I know that I am part of a great network of colleagues on whom I can count for their government information expertise. The two shared regionals in my state give excellent and exemplary service, both directly to citizens and through their backup support of the selective depositories. I would also suggest that you consider the impact your leaving the program might have on the GPO itself and that agency's ability to continue to offer its special services to libraries and to the public nationwide.

If you do decide to leave the program, it would be good to share your expertise with those libraries in your area that will continue to serve the public. This can be done through training, advising and referrals.

Suffolk University is a private university, in a large urban area, a short trolley ride from the Regional depository, Boston Public Library. We do not feel that we injured the interests of the document-seeking public by withdrawing, since there are so many depository libraries to whose missions the public is central. It would be a different matter if we were the only depository for many miles. It would also be different if service to the general public were a central part of our mission.

Law schools in particular have trouble with the public access part of the depository mission. As a group, we have been troublesome members of the depository community, often barring or restricting public access. See the bibliography for some articles on this issue. Our primary user group, the law students and faculty, feel a strong sense of ownership in the law school library, and often complain about use by even the undergraduates of our own institution. There is, then, this inherent conflict in the mission to our primary patron groups and the depository mission for public access.

There are some constantly troublesome members of the depository community that will perhaps benefit the program by dropping out. Law schools tend to select a small percentage of the materials available (we were selecting about 11%), but among those are the most expensive materials produced, such as Federal Register, U.S. Reports, CFR, Statutes at Large, U.S. Code. I believe there will be a shake-out, with libraries leaving the FDLP for whom public access was not central to their mission, and/or who did not strongly support the program either through selection of materials or spending to enhance access. I hope the result will be a stronger depository program.

After our initial decision to leave the depository program was made due to public access problems in our new building, we saw other advantages to leaving the program. In our old space, the government documents were stored in a separate library area. It was easy to restrict the documents users to that area. Though in practice, we did not really restrict them, if there were security concerns or disturbances, it was easier to feel secure in expelling problem patrons from the non-document library space. We were also moving from a fairly secluded residential section of town to a very public, high-profile location near the Boston Common. We anticipated that security concerns and disturbances might occur more frequently in our new location. With the documents integrated into the larger collection, it would be more problematic to deny access to worrisome public patrons.

I think I touched on these above in some ways. I am very concerned that GPO and the FDLP remain strong. If librarians do not speak and support the program, nobody will. No citizen realizes that he or she is going to want a government document until the day comes. Only the library community recognizes the continuing importance of free public access to government documents. I would like to see the library community work with the GPO to support their efforts to archive electronic documents and keep them in viable formats. I sincerely hope that my articles and participation on this program spark, not an exodus from the FDLP, but a shakeout of the marginal participants, and a re-commitment to the central mission of the depository program by the remaining participants.

I think it is worth considering the value of the aggregate experience of the depository community, including GPO itself. I am one who is dubious about whether FirstGov or any of the mega search engines will be able to do the job by itself to satisfy the public's information needs. The depository program has been a kind of nursery for training a lot of superb librarians, because of the variety and complexity of documents work. And I include areas such as familiarity with CD-ROMs and other electronic resources, maps and GIS applications, and much more. I would hate for the library world to lose that.

The depository program is being and will be rethought--and I would like to see enough libraries remain while this rethinking and eventual redesign is accomplished, so that a revised and renewed program can continue to make great contributions.

When a depository decides to voluntarily relinquish depository status, the procedures, from GPO's perspective, are less complicated than obtaining status.

1. The library director writes a brief letter to the Superintendent of Documents (SuDocs) stating the desire to voluntarily cease being a depository. The letter is addressed to:

Francis J. Buckley, Jr.
Superintendent of Documents (SD)
U.S. Government Printing Office
Washington, DC 20401

A copy should also be faxed to the Chief, Depository Services, at (202) 512-1432, as that office actually handles the paperwork and expedites the process.

2. SuDocs replies to the library director reminding him/her that the depository materials remain the property of the U.S. Government. SuDocs directs the depository to work with the regional librarian on the disposition of the depository materials. A Federal agency or Federal court library follows the requirements of the Exchange and Gift Division of the Library of Congress and CFR 701.33(4) governing surplus property. The highest appellate court library of a state follows the guidance in the Instructions to Depository Libraries for handling secondary copies.
3. SuDocs notifies the Regional about the library dropping status and working with the selective on the disposition of the depository materials.
4. If the library holds a representative or Senatorial designation, the Member of Congress is also notified.
5. Internal GPO staff and the microfiche contractors are notified to stop all shipments. LPS staff deletes item selections from DDIS, deletes the library's directory and Web records, posts the information in Administrative Notes Technical Supplement, etc.

These steps generally take 7-10 days from the time the letter is received in GPO.

Once the library and the Regional receive the letters from SuDocs, the timetable for disposing of the depository collection is negotiated. The disposition timetable is often 3-6 months but can last longer depending on staffing at one or both libraries. In general, the former selective depository provides two lists to the regional: 1) those holdings that the former depository wants to retain; and, 2) those materials the library wishes to dispose of. The 5-year retention rule no longer applies. The regional will evaluate the requests and direct the library in the proper procedures for discard or retention. For example, a list of major sets that the former depository no longer wants to keep may be posted to "Needs and Offers."

Retention of materials by a former depository is a privilege. A Regional may require the library to transfer specific volumes of the Statutes at Large, United States Reports, Serial Set, etc., to it. Should a former depository appeal to GPO, the SuDocs will support the Regional's claim. While the Regional has this right, it is not often exercised. Generally, the regional approves both lists.

While Sheila and the listed Web sites lay out the process for withdrawal, I would like to comment on tips that make the process smoother. Our library began the process by inquiring of the Regional and of Sheila what would happen if we withdrew. They were thus alerted to the possibility well before receiving the official letter from me. I think the early contact made a lot of difference. It also made a difference that our library had a good record of compliance with the spirit as well as the letter of the FDLP rules. Our documents librarian was active in the community and knew the regional and central administrators. I have to give huge credit to the folks at Boston Public Library, our Regional, because they were just wonderful to work with. But I am sure that if we had a history of trying to evade our responsibilities under the program, it would have been a different scenario. It would certainly depend on the outlook of the Regional administrators about withdrawing from the program, as well as towards the individual library, because the Regional is where the control resides about what materials have to be returned to the program.

One comment about the length of time to complete the withdrawal: I was just stunned at the quickness of the GPO reply after I sent my letter asking to withdraw. If you plan to leave, set up all your replacement vendors before you send the letter (though you should have called ahead to discuss withdrawing! Sheila’s story about hearing from a vendor that a certain library was withdrawing was hair-raising!).

Selected Annotated Bibliography:Evaluating the Federal Depository Library Program

Blazek, Daniel, "Private Academe and Public Depositories: Access and Promotion," Journal of Government Information, 24, no. 4 (1997): 285-311. A survey of private colleges and universities with depository libraries, looking primarily at public access and promotional activities.

Boeringer, Greta, "Federal Depository Library Status Dropped by Urban University Law School," Trends in Law Library Management and Technology, 8, no. 6 (Nov/Dec 1997). A brief article about a hypothetical law school dropping out of the depository system in order to charge access fees. The author worked at Pace University Law Library at the time of publication, but had formerly been an inspector for the FDLP.

Dugan, Robert E., and Ellen M. Dodsworth, "Costing Out a Depository Library: What Free Government Information?," Government Information Quarterly, 11, no. 3 (1994): 261-284. An excellent cost analysis done at Georgetown University. Compares the institution’s expenditures to the expenditures by the GPO in supporting that depository. Includes a selective bibliography of cost analyses and depository libraries generally.

Faull, Sandra K., Cost and Benefits of Federal Depository Status for Academic Research Libraries. Chicago: American Library Association, May, 1979. Also available as an ERIC document. This report is the earliest cost analysis study, and includes ARL member libraries which were then depositories. The information by now is aged, but the study is a model of cost analysis. It includes salary information for all staff working with documents, down to student assistants and desk aides. It factors in length of service for the personnel. It also figures the floor space, equipment costs, outreach and "program" costs, commercial reference tools, retrospective costs for materials, cost for discarding documents, cost for ordering documents, cataloging costs, and number of questions answered using Federal documents.

Heisser, David C. R., "Federal Depository Program at the Crossroads; The Library Administrator’s Perspective," Government Information Quarterly, 16, no. 3 (1999): 241-259. An interesting survey of directors and government documents librarians at twenty-four libraries, in New England, Lower South and Florida. The author actually visited and conducted in-person interviews, asking a series of questions designed to elicit the participants’ opinions on the future of the depository program. Libraries included public libraries, and public and private academic libraries in each region. The author finds strong support for the depository program and its aims, not only from the public institutions, but also from the private institutions.

Kahles, William, "Congress, Higher Education and the U.S. Federal Depository Program," Government Publications Review 13 (1986): 233-242. A legislative history arguing that the documents of twenty years show that Congress viewed the expansion of the depository program as assistance to higher education.

Kelley, Wayne P., "Commentary: Access to Depository Materials," Law Library Journal, 85 (1993): 413-415. A short but pithy article responding to recently published pieces in the same journal, and arguing strongly that depository libraries have an obligation to provide real public access to documents. The author was at the time Superintendent of Documents. The articles to which he was responding (and criticizing) were: James E. Murray, "Limiting Secondary Patrons’ Use of Academic Law Libraries During Examination Periods," Law Library Journal 84 (1992): 365; and Barbara J. Snow, "When Goals Collide: Planning and Implementing a Restricted Access Policy at the University of Michigan Law Library," Law Library Journal, 84 (1992): 383.

Kram, Lorraine, "Why Continue to Be a Depository Library if It Is All on the Internet Anyway?," Government Information Quarterly, 15, no. 1 (1998): 57-71. This is a very helpful article. The author considers how much depository material really is available on the Internet, and the prospects for change in the future. She looks briefly at the costs of being a depository and the potential savings of more electronic distribution of government information. Brief annotated bibliography of cost analyses.

Larson, Kathleen T., "Establishing a New GPO Depository Documents Department in an Academic Law Library," Law Library Journal, 72 (1980): 484-496. Interesting view of the beginnings of depositories in law school libraries. The author urges us to "evaluate both the benefits and drawbacks for such a step." She correctly spots that the primary drawback for law librarians is the right of public access, but includes other issues such as shelf space as well.

McKenzie, Elizabeth, Elizabeth Gemellaro and Caroline Walters, "Leaving Paradise: Dropping out of the Federal Depository Library Program," Law Library Journal, 92, no.3 (2000). In-depth discussion of the process of leaving the depository program at Suffolk University. Includes cost figures, details and analysis of the process and results.

McKenzie, Elizabeth, Robert E. Dugan and Kristin Djorup, "Perspectives on... Leaving the Federal Depository Library Program," The Journal of Academic Librarianship, 26, no. 4 (2000): 282-285. A brief discussion of the process of deciding and withdrawing from the depository program at Suffolk University. Analysis of replacement costs.

Morton, Bruce, "Doc Doldrums: A Response to the Documents Librarians’ Manifesto," Government Publications Review, 20 (1993): 245-247. Argues that the depository program is an entitlement program for libraries, and that the program would be better reorganized to recognize that fact.

Orr-Waters, Laura, "Love it or Leave it: Government Depositories in Law Libraries," Legal Reference Services Quarterly, 15(3/4) (1996): 133-145. Weighs the arguments for staying and for leaving the depository system. Includes cost figures for replacing basic documents and a selective bibliography.

Ryan, Susan M. "Square Peg in a Round Hole: Electronic Information and the Federal Depository Library Program," Journal of Government Information, vol. 24, no. 5 (1997): 361-375. Examines the history of electronic products and how this change in format is changing the meaning of dissemination for the depository program. Author discusses possible roles for non-depository information services, and the future for public access to government information. The author also has a book that may be of interest: Downloading Democracy: Government Information in an Electronic Age (Cresskill, N.J.: Hampton Press, 1996).

Schlueter, Kay, "Selection of Government Documents in Law School Libraries," Law Library Journal 71 (1979): 477-480. Interesting for an early view of depositories in law school libraries. Author surveyed law school libraries on the number and type of depository items selected, and found remarkably little consensus. "Documents should not be considered as being free acquisitions even when available through the depository system."

Smith, Diane H., Ed., Management of Government Information Resources in Libraries. Englewood, Colorado: Libraries Unlimited, 1993. Good chapters include discussions of the issues created by the shift to distributing documents in electronic form, and the costs and benefits of depository membership to libraries.

Way, Kathy A., "Quality Reference Service in Law School Depository Libraries: A Cause for Action," Government Publications Review, 14 (1987): 207-219. Studies the quality of reference service in law school depository libraries in the Los Angeles area. Notes the variation in quality and completeness of answers given by the degrees held by the reference librarians. The rationale behind offering depository status to law school libraries was the higher quality assistance that could be offered by librarians with greater law training.

Willis, Paul A., and Richard G. Hutchins, "Law Libraries and the Depository Program," Law Library Journal, 65 (1973): 190-212. Discusses benefits of depository membership. Surveys 36 law library depositories on their selections. Interesting illustration of law libraries’ changing attitude toward depository participation.

1. Federal Depository Library Program Background

44 U.S.C. Chapter 19

http://www.access.gpo.gov/su_docs/fdlp/pubs/title44/chap19.html

Keeping America Informed

http://www.access.gpo.gov/su_docs/fdlp/pr/keepam.html

Snapshots of the Federal Depository Library Program

http://www.access.gpo.gov/su_docs/fdlp/history/snapshot.html

2. FDLP Electronic Collection Background

GPO Electronic Information Access Enhancement Act of 1993

http://www.access.gpo.gov/su_docs/fdlp/pubs/title44/chap41.html

Managing the FDLP Electronic Collection: A Policy and Planning Document

http://www.access.gpo.gov/su_docs/fdlp/pubs/ecplan.html

Study to Identify Measures Necessary for a Successful Transition to a More Electronic Federal Depository Library Program

http://www.access.gpo.gov/su_docs/fdlp/pubs/study/studyhtm.html

3. FDLP Rules, Policies, and Program Goals

Collection Development Guidelines for Selective Federal Depository Libraries

http://www.access.gpo.gov/su_docs/fdlp/pubs/fdlm/coldev.html

Depository Library Public Service Guidelines for Government Information in Electronic Format

http://www.access.gpo.gov/su_docs/fdlp/mgt/pseguide.html

FDLP Guidelines for Substituting Electronic for Tangible Versions of Depository Publications

http://www.access.gpo.gov/su_docs/fdlp/coll-dev/subguide.html

FDLP Internet Use Policy Guidelines

http://www.access.gpo.gov/su_docs/fdlp/mgt/iupolicy.html

Guidelines for the Federal Depository Library Program

http://www.access.gpo.gov/su_docs/fdlp/pubs/fdlm/guidelin.html

Instructions to Depository Libraries

http://www.access.gpo.gov/su_docs/fdlp/pubs/instructions

Recommended Specifications for Public Access Work Stations

http://www.access.gpo.gov/su_docs/fdlp/computers/rs.html

4. Depository Termination Procedures