April 21, 2013

The members of the Canadian Federation of the Blind are deeply distressed at the decision of the government to undermine our Charter Rights by once again funding CNIB’s efforts to dominate and control our access to library services.

When Library and Archives Canada announced the Initiative for Equitable Library Access (IELA) in 2007, consumers and their organizations were nearly unanimous in saying that we wanted our right to a publicly funded, publicly managed, and publicly accountable library service. Another way to put it is that print-disabled Canadians wanted CNIB out of the library business. Initially, many consumers believed LAC should emulate the extremely successful U.S. Library of Congress National Library Service for the Blind and Physically Handicapped. LAC made it crystal clear to everyone that library services are a provincial responsibility and that LAC would under no circumstances take on a coordinating service provision role like the Library of Congress has done. Consumers and provincial libraries were left struggling to define a model of service that would provide the technical expertise needed to adequately serve our information needs while maintaining public accountability.

LAC clearly understood that there was little support for leaving CNIB in control of library services. Therefore, LAC proposed to create a new NGO to act as a national hub to carry on CNIB’s traditional library functions. Provincial libraries expressed concerns about governance and funding. Consumers, wary of yet another unaccountable private entity performing what should be a public function, demanded measures to ensure accountability. Despite intensive efforts on the part of LAC, the NGO hub proposal failed to gain wide support. IELA ceased operation without resolving basic issues of structure and governance.

While IELA was still actively working to fulfill its mandate, CNIB embarked on a political and public relations campaign to get its private library funded with public dollars. It dramatically increased the fees it charged provincial libraries for access to its collection through interlibrary loan and deposit collections. Provinces unwilling or unable to pay were told that blind people in their jurisdictions could borrow directly from CNIB. Those with print disabilities other than blindness would no longer have access to the collection, even though that collection had been digitized with 6 million federal dollars plus many more millions from private charitable donors. Those donations and federal dollars were provided with the clear intent that books would be made available to those who needed them. It is highly unlikely that anyone contributed with the intent of providing a private corporation, even one with an iconic charitable reputation, with a resource it could manipulate in order to leverage funds from provincial and federal governments.

In 2011 the Federal government awarded $7 million to CNIB to strengthen its infrastructure and to try yet again to create a hub model acceptable to Canada’s public libraries. Consumers of CNIB’s library service noticed no appreciable improvements. Print disabled people who are not blind received no service at all. A consultant spent several months in discussions with stakeholders. The result was a somewhat altered hub plan couched in general terms that still left all the outstanding issues from the earlier IELA debacle unresolved.

While CNIB was engaged in its very public political activities, provincial libraries responded to IELA’s collapse by carefully building a consensus around a collaborative interprovincial system for sharing and developing accessible materials. They chose to build through open interprovincial discussions. They researched sources of alternate format books in addition to materials held by CNIB, determined the extent of unrestricted collections held by public libraries that met accessibility standards, and sought effective means to apportion responsibilities to avoid duplication of effort. They entered into a collaborative relationship with the Library for the Blind of Western Australia and other members of the Commonwealth …; that partnership alone resulted in the capacity to provide more than seventy thousand titles in restricted alternate formats; more than 20,000 of those titles are currently available for download. (It is worth noting here that the Library for the Blind of Western Australia offered its collection and download software to Canada without charge, while CNIB withheld its collection from Canadian libraries even though taxpayers had helped pay to digitize it.)

In November, 2012, the Provincial and Territorial Public Libraries Council (PTPLC) voted approval of the National Network for Equitable Library Services (NNELS), the name chosen for this initiative. Testing has been carried out on the open source software used to manage the downloadable content received from the Commonwealth. The system is up and functional; books can be accessed now.

The details of the NNELS initiative have been discussed very openly within the library community. Unfortunately, NNELS has not done nearly as well at publicizing itself as CNIB has done. As a result, those not intimately involved with the issue are unaware that Canada now has a choice of two very different library service models.

The Canadian Federation of the Blind believes the NNELs model offers more promise for equitable and integrated service. We believe NNELS is more politically accountable, capable of leveraging a wider variety of resources, and can build capacity for production of specialized formats beyond that which can be provided by a single source model.

– The NNELS model puts the responsibility for serving Canadians with print disabilities squarely on the desks of provincial librarians. Consumers unhappy with the level or quality of service know exactly where to take their issues.

– The hub model leaves the provinces responsible for funding and the operator of the hub (CNIB) responsible for service. Unhappy consumers who complain to their provincial librarians are likely to be told to take it up with CNIB. When consumers complain to CNIB, the response will almost certainly be “We’d be happy to do more if only the provinces would provide more money.”

– Because NNELS is committed to leveraging both restricted format and unrestricted format digital collections, print-disabled library patrons will be in a stronger position to insist that accessibility be a top priority in the acquisition of all digital library materials.

– If service to the print-disabled is viewed as being outside the regular functioning of the library, something purchased from a single specialized provider, public libraries will be far less likely to incorporate universal access into their acquisition decisions.

Even if only a small fraction of the total capacity of Canada’s libraries is brought to bear on issues having to do with print disability, the synergistic combination of those resources will result in a much greater capacity than would be available to any single hub.

Truly excellent alternate format service requires that the libraries providing it have knowledgeable production specialists, especially for math and music Braille. Because it will actively seek bids from a variety of potential suppliers, NNELS is positioned to seek expertise from many sources, including small businesses operated by knowledgeable blind producers. Clearly CNIB would be free to bid on any contracts for specialized production.

Building capacity throughout Canada will ultimately lead to more available materials. Relying on a single source provider such as CNIB will have the opposite effect.

The Federal role in the development of the saga of dueling library systems has been mixed at best. To its credit, the government did create the IELA process which allowed broad discussion of options and helped strengthen the understanding that people with print disabilities have the right to information. It is unfortunate that IELA and the Federal government have so far been unsuccessful in facilitating results in harmony with the expectations the process raised.

Throughout the entire IELA process and afterward, the Federal government clearly signaled to all involved that libraries are a provincial responsibility. Why, then, is that same Federal government now inserting itself in a manner calculated to undermine the efforts of the provinces to carry out that responsibility?

The Federal government must begin to conduct itself in such a way that the CNIB hub model no longer has an unfair advantage. In fact, given its insistence on provincial responsibility, the Federal government is obligated to do all that it can to support moves toward accountability on the part of the provincial libraries.

We suggest several steps the government can take to undo the damage it has done with this recent
announcement. The most appropriate decision would be to rescind the budget announcement.

Failing that, we suggest the following.

1) One of the conditions for CNIB’s receipt of the $3 million of promised Federal funding would be a contract requirement that CNIB provide NNELS with digital copies of its library collection. The Federal government has already paid to have the collection digitized; arguably, that collection is now a public resource. As a matter of reciprocity, NNELS should be invited to reciprocate and provide CNIB with its digital downloadable collection of alternate format materials. However, since NNELS is not being offered a Federal contract, reciprocity could not be mandated but would be a result of a spirit of collaboration.

2) As part of its contract, CNIB should be required to inform all of its library borrowers of the availability of service through the NNELS system. Text for the notification should be provided by NNELS and distributed by CNIB without alteration or comment. The distribution should be regarded as part of the contract deliverables.

3) In the interest of equity, NNELS should receive equal funding. If funding is equal, requirements for reciprocity in collection sharing and in notification of the availability of CNIB library services could be imposed equally on NNELS.

If the government made the decision to provide CNIB, and only CNIB, with funding because it was unaware of NNELS, the situation can be rectified now that government has more complete information. Canada has the potential to build an integrated library service for the print-disabled so forward thinking that it could become the model for the digital age. Or Canada could decide to retain old patterns and the restrictive and antiquated thinking they represent. The Canadian Federation of the Blind urges Parliament to insist that innovation be recognized so that Canada once and for all can move toward a truly accountable public library system that serves blind people as the equal Canadians we are.

Very truly yours,

Mary Ellen Gabias, President
Canadian Federation of the Blind