Ms. Martha B. Gould
Chairperson
U.S. National Commission on Libraries and Information Sciences
1110 Vermont Avenue, NW
Suite 820
Washington, DC 20005-3552

Dear Ms. Gould:

On behalf of the Computer & Communications Industry Association (CCIA) I would like to thank the Commission for allowing us the opportunity to comment on the Comprehensive Assessment of the Federal Government’s Public Information Dissemination Policies and Practices. We commend the Commission for its hard work in producing this excellent document.

After reviewing the final report, CCIA is in general agreement with most of the report's text and purpose. However, we would like to offer some additional comments in areas that we believe the report needs clarification or should take a stronger position.

Throughout the report, particularly in the "Findings Relating to the Commercial (For Profit) Sector," the Commission stresses a need for the government to enter into public-private sector joint partnerships to assist with information dissemination. CCIA agrees with this position, believing that these associations maximize the use of government information and provide the public with easy access to government information. However, we would encourage the Commission to place greater emphasis on the importance of an open process in public-private sector joint partnerships. It is essential that all private sector organizations must have equal opportunity to join in these government partnerships -- the government should not employ partnerships that discriminate against some private firms while bolstering others, in effect picking "winners" and "losers." Additionally, CCIA believes that when the government enters into a partnership for the compiling and dissemination of information, it should not permit the private entity to assert exclusive control over the underlying information and data, regardless of any value-added services or compilations the private firm creates to make use of the data easier. Public information must remain available to the public notwithstanding any additional use or manipulation of the basic data by a private-sector partner of the government.

Another aspect of the report on which CCIA would like to comment is the "Conclusions Relating to Individual Citizens (the General Public)." While the recommendations calling for a "yellow pages" approach to the dissemination of government information are commendable, CCIA would advise the Commission to address potential privacy concerns of the general public. There is a need for the government and its partners to respect the users' right to privacy and desire to remain anonymous. Since much of the information collected by the government may be obtained involuntarily or with the expectation of confidentiality, the public must have confidence that the information it provides to the government and its partners will not be given out to third parties or other government agencies.

CCIA would also urge the Commission denounce government information dissemination activities that improperly compete with the private sector. While this concern is evident throughout the document, it should be stated more specifically in the report's conclusions, along with appropriate guidelines for government activities. In the report, the Commission quotes the study commissioned by CCIA, The Role of Government In A Digital Age, in connection with a discussion on the activities of the National Technical Information Service (NTIS). While we agree with its relevance to this section, CCIA believes the full report provides a useful framework for the activities of government generally, and for information dissemination activities specifically. We encourage the Commission to utilize the report in evaluating the activities of the government and to strengthen its conclusions by calling for the government undertake a similar assessment when providing services to the public. In particular, the government should be extremely reluctant to undertake any activity when private-sector firms currently provide similar services in a competitive market, or if the private sector could be incented to provide the service. The government should offer value-added services only as a matter of last resort.

CCIA strongly endorses the recommendations that call for cooperation between Federal agencies, the private sector, and library providers to enhance access points and consideration of non-exclusive partnerships with these groups. Enhanced cooperation will result in a more educated populace in regards to government activities and policies.

Members of CCIA support the principles of open access and dissemination of government information, but stress there must be safeguards to ensure wide availability, fair competition, and checks on improper government intervention. We appreciate the opportunity to comment, and hope to work with the Commission in the future.

Sincerely,

Edward J. Black
President and CEO