Mr. Robert S. Willard, Executive Director
National Commission on Libraries and Information Science
1110 Vermont Avenue, N.W., Suite 820
Washington, DC 20005-3552

Dear Mr. Willard;

The American Library Association (ALA) appreciates this opportunity to comment on the NCLIS "Emerging Consensus Position Paper." Timely and systematic access to unclassified federal scientific and technical information (STI) is of vital importance to the economic well-being and security of the nation.

ALA has long-standing policies supporting the broadest and most effective access to all kinds of government information. We are on record urging the federal government to provide for a centralized source and permanent repository for a broad range of federal, international, state, local, and other unclassified government information, including scientific and technical information (STI).

ALA strongly endorses the NCLIS statement that "The collection and dissemination of government information for the public is fundamentally a governmental obligation." This obligation extends to activities that support and facilitate the public's ability to efficiently identify, locate, access, and obtain historical and future unclassified STI materials.

ALA urges NCLIS to support initiatives for Congress to pass legislation to transfer these centralized STI clearinghouse functions to the Government Printing Office (GPO).

ALA members believe that GPO -- through its partnerships with the Library of Congress (LC) and other national libraries, with the National Archives and Records Administrations (NARA) and other federal agencies, and especially with the 1,350 academic, public, and other libraries that comprise the Federal Depository Library Program (FDLP) -- is in the best position to successfully carry out the STI dissemination and related functions handled currently by NTIS. ALA believes that:

• Combining the NTIS STI functions with similar services provided already by GPO creates a single, comprehensive, and efficient STI collection that will decrease duplication and increase easy access for researchers, businesses, and the American public;

• Including reports from the NTIS archival collection as well as current and future electronic STI reports in the FDLP, enhances public access to this important information and is clearly in the public good;

• Having a centralized bibliographic source and making the indexing, abstracts, and reports available through the FDLP for no-fee public access serves the public good and returns the public investment in federal research and development;

• GPO has wide experience in cataloging or coordinating the description of documents in all types of media as well as working with LC, ALA, and other groups in developing national standards for bibliographic control;

• GPO has been a leader in developing guidelines, practices, and partnerships to permanently access electronic documents for ongoing and future use. This experience is especially relevant as agencies are increasingly using the Web to disseminate STI;

• GPO has broad experience and expertise in large-scale distribution and sales of government information (selling more than 19 million publications per year in multiple formats) and GPO already has responsibility for printing, procurement, and dissemination of all formats of government information.

ALA also strongly agrees that the Congress should eliminate the statutory requirement that operating costs for NTIS associated with the acquisition, storage, bibliographic control, and archiving of information and data shall be recovered primarily through the collection of fees (P.L. 102-245, Section 3704b-1). As "public good" functions inherent in the public's ability to access federally-funded STI, these should be covered by appropriated funds.

ALA agrees that further, systematic study should be conducted to investigate carefully the benefits and costs of implementing any viable alternative focusing especially on a transfer to GPO. ALA's analysis is that the public good is best served by transferring the NTIS functions and collections to GPO. The short- and long-term alternatives identified by NCLIS help to underscore this point:

The NCLIS "short-term" options include retaining NTIS in the Department of Commerce (DOC) or transferring the collections and services responsibilities to LC, NARA, and/or GPO. Of the agencies mentioned here, only GPO has the breadth and depth of experience to successfully coordinate and/or carry out the key clearinghouse and public access functions (e.g., acquisition, organization, description and indexing, dissemination, production, permanent access, sales) to improve and enhance access to STI materials.

Moreover, GPO is uniquely positioned to cooperatively partner with LC, NARA, other federal agencies, and non-governmental entities to fulfill this mission. The GPO-NTIS pilot project is another example of cooperation and should be continued and expanded even as these discussions continue.

The NCLIS "long-term" alternatives provide interesting but ultimately unsatisfactory options for addressing all of the public access concerns regarding federally-funded STI:

• Establishing a new science, engineering, and technology national library is a worthy goal supported generally by the library community, but would not alleviate the present and ongoing need to provide clearinghouse and public access functions currently performed by NTIS. It is reasonable to assume that the new national library, while a key partner in providing access to STI, likely would serve a fundamentally different mission. Such a library would fill a different role than those embodied in the NTIS functions, just as the other national libraries (LC, National Agriculture Library, National Library of Medicine, National Library of Education) presently do.

• The missions, expertise, and practices of the National Academy of Sciences, the National Science Foundation, and the Smithsonian Institution do not include the clearinghouse and public access functions on the scale required to take on the NTIS responsibilities. Considerable changes in the fundamental roles and cultures of these agencies would be required to envision such an alternative, at the expense of taking advantage of other agencies (i.e., GPO) already suited to carry out these functions.

• The concept of creating a new independent agency to consolidate public information dissemination functions now dispersed is worthy of further study. However, the political viability of such an idea should be assessed seriously before considerable effort and expense is expended toward this end.

ALA is deeply concerned about the possibility of privatizing some NTIS activities. As stated above, ALA believes that the clearinghouse and public access functions performed by NTIS are fundamentally governmental responsibilities to promote the public good and thus should be funded by congressional appropriations. Further, there appears to be wide consensus that the business model of cost-recovery is at the core of NTIS' present problems, and the private sector is unlikely to want to take over any activities that are not likely to sustain themselves. Relying exclusively on the private sector for key NTIS functions would likely result in reducing public access to federally-funded STI. Moreover, the coordination and provision of NTIS functions by the government does not preclude the private sector from stepping in to provide additional or enhanced services that the market requires or desires.

In the final analysis we believe that the best alternative for a short and long term solution is the transfer of collections and service responsibilities to the Government Printing Office. The STI materials, especially the bibliographic tools, would and should be made available to the American public through the Federal Depository Library Program as well as through the GPO sales program. The similarities of the GPO and NTIS missions and skills would realize economies of scale as well as a potential synergy between the staffs and resources of the two organizations.

This is a "timely window of opportunity" that allows us all to discuss how best to improve public access to information. We agree with NCLIS that the NTIS issue, "while an urgent and important challenge that must be resolved quickly, must be regarded as part of the larger and longer standing Title 44 problem of ensuring effective, equitable, and efficient public access to Government Information." This is truly an opportunity to "get it right" and to delve into issues of agency compliance, ongoing permanent public access to tangible and electronic information products and many important access issues.

The larger question is "how to strengthen Government information dissemination to the public in the Information Age, including finding mechanisms to ensure agency compliance with public dissemination and permanent preservation efforts." The American Library Association stands ready to work with you, the American public and all other stakeholders to address these many complex issues.

ALA will be providing additional comments to NCLIS and will be participating in all venues and forums where this debate proceeds. Thank you for this opportunity to comment.

Sincerely yours,

Chadwick Raymond, Chair
ALA Committee on Legislation

Enc. - ALA Resolution on No-Fee Permanent Public Access to Scientific and Technical Information