MINIMUM STANDARDS FOR ACCREDITATION OF PUBLIC LIBRARIES IN THE STATE LIBRARY SYSTEM
Comments Submitted
Comments on §1.71 Definition of Population Served
Comments and Suggestions: Does this definition adequately cover tax district libraries? I suggest they be specified as a library type.
Comments and Suggestions: Will library districts population served still be calculated the same way as it currently is or will that change also?
Comments and Suggestions: Item 7. The estimation of population served when funded by a school district needs to have some relation to the size of school district. Our school district is the main source of funding for our library and has about 1500 students. The state library continues to look at total population within school district boundaries and assigns us a population of more than 8000. The issues of funding when such a tremendous gap exists unduly burden school district and library during the accreditation process. Exceptions are allowed for libraries accepting county funding because of the assignment of an unrealistic population figure. Further exemptions are granted to libraries where the population served contains correctional institutions or military installations. So exceptions are made. Presently an institution that actually supports 1/8 of the population is being expected to fund library services for the total population of the district. Please consider the financial reality of that situation.
Comments and Suggestions: How do you determine populations for library districts?
Comments and Suggestions: Section 8 - " . . . enter into agreements . . . with . . . cities . . . will be assigned population . . ." A possible scenario - two cities enter into a formal agreement to allow reciprocity in library services. Money is not exchanged but by this rule populations are significantly enlarged. This could have a serious impact on required maintenance of effort required for accredidation?
Comments and Suggestions: Allocated is less confusing & most of us use Census data. It should be readily available for all towns and cities via the web.
Comments on §1.72 Public Library Service
Comments and Suggestions: There seems to be ambiguity as between (a) "admissions to the facility or any programs...." and (b) "facilities;".
Comments and Suggestions: (b) retain "use of" before "facilities" for proper sentence structure.
Comments and Suggestions: Agree with the comment "(b) retain "use of" before "facilities" for proper sentence structure." And it would also clarify the revision.
Comments and Suggestions: The document "says" (b) The following charges are permitted at the discretion of the library's governing authority: reserving library materials; facilities; "Facilities" needs some additional information...that is...you are identifying areas where charges or fees are acceptable...so RESERVING library materials are an area...REPLACEMENT of lost borrower cards, etc..so you need something other than "just" facilities such as "use of facilities"
Comments and Suggestions: (b) "facilities" -- to vague as a stand-alone word. There needs to be a verb or descriptor also.
Comments and Suggestions: The change from charging for the use of meeting rooms to just saying facilities is not very clear. Can libraries charge to use bathrooms (facilities) or the enter the building (facilities)? A common question that comes up regularly deals with rental and deposits for books and other materials. The rule specifically says rental fees or deposits are acceptable for equipment. That seems to clearly preclude rental collections for bestsellers (a service provided by libraries in some other states) and deposits for test study guides and such but as it is not specifically stated some people have tried to interpret books and DVDs as "equipment."
Comments and Suggestions: Why was use of crossed out regarding facilities?
Comments and Suggestions: (b) end of first line. use of should not be struck, otherwise facilities makes no sense.
Comments and Suggestions: Our non-profit library rents our meeting room which is accessible from the lobby and can be used when the library is closed. The small meeting rooms inside the library are available free of charge during library hours. Our building was designed so that we could use our meeting room as an income source. The marking is unclear as to whether we would be allowed to charge for that room or not.
Note from TSLAC: "use of" is retained in the rule. This was a typo in the form that has been corrected.
Comments and Suggestions: I agree with changes.
Comments and Suggestions: Suggest to add into the criteria a definition of "general public".
Comments and Suggestions: Section b: Clarify "charges for the use of materials and machine readable data bases not owned by the library for which the vendor or supplier has charged a borrowing fee" Does this include services such as Overdrive or Freading for which a library must pay a subscription fee? Clarification from TSLAC: No, this does not include these services.
Comments on §1.73 Public Library: Legal Establishment
Comments and Suggestions: Should this section mention the Local Government Code CHAPTER 323. COUNTY LIBRARIES?
Comments on §1.74 Local Operating Expenditures
Comments and Suggestions: The increase of over 29% for per capita spending seems to be a sizable jump. Although this would not negatively affect us, I wonder how many libraries would not meet this newer figure.
Comments and Suggestions: Why are you raising the minimum total local expenditures so drastically from $10,000 to $18,000? With no state financial support now that Loan Star is done away with, how are small libraries supposed to keep up with these requirements or are we trying to do away with small libraries?
Comments and Suggestions: Continuous growth is important, however, too many libraries are facing budget cuts. By increasing the amounts for the per capita exemption, you are placing an even larger burden on these libraries. This will push more and more to become unaccredited.
Comments and Suggestions: These increases are too high considering the economy in general. We were fearful that we would not make the standard this year.
Comments and Suggestions: This seems a frightening prospect for libraries and communities facing economic downturns; and for those of us experiencing "booms" right now, it is frightening to think what might happen when/if the "boom" goes away.
Comments and Suggestions: Why keep increasing the standard when the State has cut funding all together and local support is decreasing?
Comments and Suggestions: These figures seem to be quite an increase, especially local expenditures that almost double in 2016, 2017 and 2018, and more than double in 2019, 2020 and 2021. Rural communities are seeing a decline in population as well as allocated funds. Libraries already compete for limited funding in our small town and cannot often count on increases from local entities. I feel that these figures should be revisited and a lower increase considered across the board.
Comments and Suggestions: City and other local government revenues are not constantly maintained or increased. It is unrealistic to expect library expenditures to do so when there is a local downturn in revenues. The exemption for libraries spending $13.50 per capita provided a useful alternative in such cases. Raising that to $17.50 seems inappropriate in the current economy. A better solution might be to explicitly allow for a reduction in library expenditures proportional to any reduction in local governing body revenues.
Comments and Suggestions: How many active libraries would not meet this criteria this year? We all want to see libraries receive more funding but realistically this may just flat be out of reach of many of the scourmall libraries. Of course, with the slash in TSL funding, the collapse of systems, and the transfer of responsiblity of interlibrary loans to individual libraries, what are the negatives of not being accredited?
Comments and Suggestions: Our county commissioners court is strongly against the proposed changes above. They believe it will place undue hardship on county resources as the requirements rise. Some counties would see a 140% increase.
Comments and Suggestions: While I would love to see libraries receive more and more funding including my own I feel this is unrealistic. We have been having a very difficult time meeting the standards already set. The county has been reducing our funding on a yearly basis. We would like to remain part of a group of libraries as we are now but this will be very difficult to do perhaps even impossible with these high standards and the smaller libraries in our group will suffer from this. I hope you reconsider the increases you are proposing. I understand that everything rises but unfortunately our budgets do not.
Comments and Suggestions: These are probably necessary changes, but 10,000 to 18,000 or 24,000 or 21,000 is doubled. That is a big jump.
Comments and Suggestions: Using data for FY2012 the change from $10k to $18k increases the number of noncomplying libraries from 36 to 66. In every instance these libraries are missing other, currently existing criteria for accreditation - most commonly lack of a MLS librarian. Is a library with so little financial support (and remember that these numbers only put into play a requirement that the local operating expenditures increase above a rolling three year average) a book collection or a library? Clarification from TSLAC: It appears that this commenter is referring to Question 4.3, Local Government Expenditures, when they state that 66 libraries will not meet the new minimum for this rule. However, it is Question 4.2, Local Operating Expenditures, that is used to determine whether a library meets 1.74. Based on the LFY2012 data, there are no member libraries that do not currently expend the minimum local operating expenditure amount of $10,650. Should this rule be implemented, there are 12 currently accredited public libraries that may not meet the $18,000 minimum local operating expenditure criteria.
Comments and Suggestions: Although these increases are significant, I feel they are necessary to be able to provide a base level of services to a community.
Comments and Suggestions: What does 'at least $150,000 of local funds are exempt from this membership criterion' mean?
Comments and Suggestions: I agree with changes.
Comments and Suggestions: I think the increase is too much. We would have to almost double our total local expenditures. We are a rural public library with a limited budget. This change would force us to be non accredited. Would there possible be a exemption for libraries serving a population of 5,000 or fewer? I think the libraries that are going to get weeded out are rural libraries. And this is going to effect low income families that have the library as there only access to communication and resources. A lot of libraries in rural areas are essential to communities.
Comments and Suggestions: We are a small rural library with a small tax base. It is very stressful every year to increase our spending. Our annual budget is less than $150,000. This year alone we lost $4,000 funding from the city government and $5,000 funding for our collection from the Tocker Foundation. And this is in a good economy. It seems this goes against principle #2 of the Accreditation Principles and #9b. We do not know what financially lies ahead from year to year, and to raise the minimums could potentially make accreditation unattainable for small libraries. Not being accredited would mean no grants from TSCAC which really seems wrong for libraries that strive to do their best with the means they have.
Thanks for opportunity to be heard on this topic.
Comments and Suggestions: A 33 % increase in a stagnant budget economy may be too difficult to meet.
Comments and Suggestions: My city manager is prone to balk at this as he already feels the tail is wagging the dog (or vice versa). I understand the need for the increase, but in these times, this will be a hard, hard sell.
Comments and Suggestions: With budget cuts it is getting harder and harder for our tiny library to stay accredited now.... Please don't make it even harder!
Comments and Suggestions: This will create a hardship for municipalities that are undergoing budget cuts.
Comments and Suggestions: Someone mentioned (above) that, "A better solution might be to explicitly allow for a reduction in library expenditures proportional to any reduction in local governing body revenues." This would be much more fair than expecting every funding entity or group to come up with increased allocations for libraries despite any reductions or flattening of the entity/group's own budget for that same year.
Comments and Suggestions: Increasing the "minimum total local expenditures" requirement from $10,650 in 2013, 2014 and 2015 to minimums of $18,000 in '16 - '18, $21,000 in '19 - '21 and $24,000 in '22 - '24 reflects a TOTAL increase of 125% in REQUIRED expenditures within a period of seven years. (2023 and 2024 reflect no increase over 2022.)
The disproportionate increase in required expenditure for small libraries is especially disturbing in view of these facts:
* More than 30% of public libraries in Texas serve populations under 5,000. Half of those serve populations under 3,000.
* CURRENTLY 51 counties in Texas have populations less than 5000. 7 counties in Texas have populations less than 1000. 130 counties in Texas have only one public library or public library system. 7 counties in Texas nave no public library at all.
* The Task Force group addressing Accreditation included no members representing libraries serving populations under 5,000. In fact, only one of the 19 Task Force members came from a library serving a population of less than 10,000, despite the fact that more than half of Texas public libraries serve populations less than 10,000. The single representative came from a library that serves a population of only slightly less than 10,000.
The disproportionate increase in required expenditure for small libraries will discourage development and maintenance of libraries within reasonable driving distances in rural or sparsely populated areas, places where high speed Internet is widely unavailable and where Texans may be in need of the services, programming and training libraries can offer. For many Texas residents in rural areas, the "small" library is their only connection at least some of what is available at other public libraries in the State - provided the small library can qualify for accreditation, participates in ILL AND can afford to invest in the databases. Increasing standards so dramatically, especially when so many cities and counties in the state are struggling to make ends meet, will have an equally dramatic impact on the number of accredited public libraries in Texas.
Why do accreditation standards provide no incentive or reward for strong statistics related to circulation, visits, programs offered or other services when related data is already being collected through the required annual reports?
Comments and Suggestions: It is unrealistic to increase the minimum local expenditures at a time when many communities are hard hit economically and the rural libraries have not only lost state funding but have lost their systems. Don't increase when total revenue is trending down. Give the economy more time to recover before increasing requirements. The result of increased requirements will be loss of accreditation for many small libraries and setting of an impossible goal for small libraries struggling to meet present minimums. There are no longer any useful benefits to accreditation other than the access to TexShare Databases and to competitive grants. Realistically, local governments will see no benefits for access to TexShare, and MIGHT see benefits to access to competitive grants, but when it comes to budget crunch times, libraries will still get a smaller portion of the city budget than police, fire, sewers, and road improvements. No recognizable benefits for achieving accreditaton do not make good talking points at budget time.
Clarification from TSLAC: The $17.50 per capita in 13 TAC §1.74 is not a minimum, but rather an exception. Currently, the rule says if a library expends at least $13.50 and $125,000 in local funds on operating expenditures, then the library is exempt from MOE. The proposed change is to increase the exception to $17.50 and $150,000 in local operating expenditures. It is NOT the minimum a library must expend.
Comments and Suggestions: What useful purpose does it serve to increase the minimum local operating expenditures? At a time when many neighborhood libraries are struggling to maintain their current funding levels, while their cities are struggling with expensive infrastructure changes needed because of expanding populations, it can only result in less support for small libraries. From the city government standpoint, it is just another unfunded mandate among many. To them there are no appreciable values to library accreditation that make up for the increased drain on city budgets. While they might in theory feel libraries are important cultural centers, the budget crunch forces them to say "no" to increased spending levels. Unfortunately this comes at the same time when the current feeling is that libraries are no longer needed because of internet, ebooks, downloadable audio, increasing capabilities of cell phones. WE know libraries aren't superseded but our funding sources have increasingly bought into the current fallacy. So why should they continue to increase funding? The result: there will be fewer neighborhood libraries accredited, which means more small libraries will not be able to provide the TexShare databases, and will not be able to apply for competitive grants. These two things are the best reasons for libraries to try for accreditation, but only the second would speak loudly enough at budget time to have any affect on the numbers crunch. It becomes an increasingly futile attempt to reach an impossible goal. Please keep local operating expenditures at the current level until our economy does turn around in truth, not in hopeful dreams.
Comments and Suggestions: Is the intention that, to be accredited in Texas, a public library must be well-funded by local taxes? Is local funding a true reflection of how a public library in one community compares with libraries in other communities?
Comments on §1.75 Public Library: Nondiscrimination
Comments and Suggestions: There is no need to change 1.75. Leave it as it was.
Comments and Suggestions: This is an excellent addition to this section.
Comments and Suggestions: Is there a place to deal with home ownership or temporary residency in a community? At least one library I know has a policy that they do not give library cards to renters on the assumption that they are not Texas residents because they are renting for less than a year.
Comments and Suggestions: I agree with this change.
Comments and Suggestions: This is an important and well written update to this section.
Comments and Suggestions: It's about time libraries added "sexual orientation" to its non-discrimination list, and others!
Comments and Suggestions: Good idea.
Comments and Suggestions: I support this change.
Comments and Suggestions: change sex to gender
Comments and Suggestions: Too specific and seems to be pandering to a an overly PC mentality that fosters hypersensitivity and defensiveness.
Comments and Suggestions: Very appropriate and well-worded.
Comments and Suggestions: I agree with changes.
Comments and Suggestions: Both the criteria and the form each have non-discrimination criteria that do not appear on the other. The form should match up with the stated criteria and there need be statute citations for all of the items listed.
Comments and Suggestions: Ditto to changing sex to gender.
Comments and Suggestions: The Americans with Disabilities Act of 1990 and Revised ADA Regulations Implementing Title II and Title III should be included. Omitting such an obvious statute from the list, especially at a time when many libraries in the country are encountering legal issues relative to eReader access, does not make sense
Comments on §1.77 Public Library: Local Government Support
Comments and Suggestions: Per capita should be lowered to $15.50.
Comments and Suggestions: What impact does this have on 501c3 libraries that receive little or no governmental support? Does this mean they cannot be accredited?
Comments and Suggestions: Our county commissioners are strongly opposed to this change.
Comments and Suggestions: I agree with changes.
Comments and Suggestions: $15.50 seems to be more reasonable. Although according IMLS data recently published, the state average is over $19.
Comments and Suggestions: My comments for 1.74 also apply here: We are a small rural library with a small tax base. It is very stressful every year to increase our spending. Our annual budget is less than $150,000. This year alone we lost $4,000 funding from the city government and $5,000 funding for our collection from the Tocker Foundation. And this is in a good economy. It seems this goes against principle #2 of the Accreditation Principles and #9b. We do not know what financially lies ahead from year to year, and to raise the minimums could potentially make accreditation unattainable for small libraries. Not being accredited would mean no grants from TSCAC which really seems wrong for libraries that strive to do their best with the means they have.
Thanks for opportunity to be heard on this topic.
Comments and Suggestions: This will create a hardship for municipalities that are undergoing budget cuts.
Comments and Suggestions: [Our library] is a nonprofit - 501(c)3. We receive minimal support from the city and county - about 17% of our approximate $32,500 budget. We have always met expenditure standards on the 3 year average and have run about $14.50 per capita. The county gov't spends most of its library budget on the official county library. The city government has made it clear they will NOT increase their funding for us. If we have to meet the new $17.50 per capital rule, or get 50% of our funding from local gov't, we are doomed to fail. We are a national award-winning library because of our local donors and our volunteers. Our patrons should not loose their good library services just because our city gov't has their heads in the sand. As long as we're providing good service and meeting minimum expenditure standards, why does it matter whether the money comes from the city, county, or local supporters?
An exception should be made to this rule for libraries that are not city- or county-owned.
Comments and Suggestions: When funding support is trending down, it is not realistic to increase the per capita expenditure requirement. Small libraries will have difficulty reaching $17.50. Would like to see it remain at $13.50. Wherever local governments are having to continue budget cuts, many small libraries will have difficulty increasing government funding. Fewer libraries reaching or retaining accreditation will mean fewer library services available in rural areas.
Clarification from TSLAC: The $17.50 per capita in 13 TAC §1.77 is not a minimum, but rather an exception. Currently, the rule says if a library expends at least $13.50 in local funds on operating expenditures, then the library is exempt from the local government expenditure criteria, so long as it expends some funds from a local government source. The proposed change is to increase the exception to $17.50. It is NOT the minimum a library must expend.
Comments and Suggestions: The word "citizens" in (a) should be changed to "community residents."
Comments and Suggestions: IMLS data referenced in a comment above reflects stats from libraries submitting information, not to all existing public libraries in the state, so that state average isn't completely reliable.
Comments on §1.79 Provisional Accreditation of Library
Comments and Suggestions: The wording of (b) suggests that the library could fail to meet two OR MORE requirements and still be provisionally accredited. Is that the intention?
Comments on §1.80 Probational Accreditation of Library
No comments submitted.
Comments on §1.81 Quantitative Standards for Accreditation of Library
Comments and Suggestions: include the verb "have" in all instances of (C) "...at least..." to retain proper sentence structure.
Comments and Suggestions: 8.C. requiring at least 1% of collection published in the last five years is too recent for small, poorer libraries and the standard should be omitted.
Comments and Suggestions: I do not like the dilution of standards for publishing: 1% of collection published in the last five years is ludicrous. I would prefer to maintain the current requirements of 15%; 20% and 25%. This is a goal for which all libraries should strive.
Comments and Suggestions: Reasonable.
Comments and Suggestions: Small libraries offer services to patrons that cannot be measured monetarily. Very often the per capita rate cannot be reached, but a value cannot be placed on one-on-one consultations with patrons. I don't agree with (c). It is not up to the state library to determine what materials are contained in a library's collection at any given time. When funding goes down we often rely on donations, whether they be money or items, to be placed in the collection.
Comments and Suggestions: Professional librarian- I feel that you are discriminating against highly qualified librarians that have a degree from a non ALA accredited university. The program in a non ALA accredited is just as rigorous and relevant as the program from an ALA accredited program as I have personally witnessed from being a mentor to librarians in each program. We were hired because of our qualifications and our ability to have successful library programs.
Comments and Suggestions: C) at least one% of the collection has to be less than 5 years old seems very low. A collection of 100,000 items would only need to add 200 newer items every year. Also people are confused about "publication" date. Is a copy of the Great Gatsby published in 2014 with a new ISBN for that edition a book published in the last 5 years? No distinction between copyright and publication date?
Comments and Suggestions: The new criteria to have at least 1% of collection should be published in the last five years is just pitiful. At least make it 10%. What is an "equivalent' professional librarian.
Comments and Suggestions: Our county commissioners are strongly opposed to this increase.
Comments and Suggestions: "employ a library director for at least 40 hours per week in library duties; and (EF) employ at least one full-time equivalent professional librarian." Could the library director be the full-time professional librarian or does that need to be an additional position?
Clarification from TSLAC: The professional librarian could be the director, but does not have to be. Per §1.84, a professional librarian is “a person holding either a fifth year degree in librarianship from a program accredited by the American Library Association or a master's degree in library or information science from a program accredited by the American Library Association or a higher credential from a library school offering an American Library Association-approved program in library or information science.”
Comments and Suggestions: The 1% collection items published in last five years is a step in the right direction, but given ebooks, etc. it is much to low. It would be better to focus this on non-fiction and set the threshold at at least 10%.
Comments and Suggestions: I can't imagine having the money to have a branch open and staffed more than 48 hours per week. Fifty-four and 64 seem almost impossible. I see that these requirements are not new, so there must be some special rules about how the hours are counted.
Comments and Suggestions: The 1% of total items in collection published in the last five years is something we can take to managers and say we need to have money to make the collection current and relevant in order to be accredited.
Comments and Suggestions: section B - 15% towards materials would be too high EXCEPT that, in conjection with the "or" regarding items per capita, it becomes reasonable. The proposed changes don't eliminate that "or" but I want to reinforce the importance of it.
Regarding hours -I suspect it is total unduplicated hours and there may only be one or two libraries that do not meet the requirement for their population category.
Comments and Suggestions: In questions 1-8 (C), I think asking for only 1% of a public library's collection to be less than 5 years old is a travesty. The percentage of new materials should be much higher, at least 20%. We are reading libraries, not tombs for old books.
Comments and Suggestions: Although the per capita requirements may appear to be very high, I feel they are reasonable if we are to provide any baseline level of quality service in public libraries. Perhaps libraries who cannot yet achieve or maintain these levels of funding, could be accredited as a "reading room" rather than a public library, recognizing the differences that funding makes in providing services??? Ideally there would be a lesser level of direct funding provided by TSLAC for "reading rooms" rather than "public libraries" , but also a greater amount of mentoring/guidance in developing the structure, and professional and financial underpinnings necessary to attain the accreditation level of "public library." This idea has been talked about for the last 20 years or so as a possible solution to the problem of quantitative public library standards that remain too low for some libraries to use effectively with their funding bodies
Comments and Suggestions: The basic issue with accreditation standards is that these are largely predicated on financial support. As with other areas of government and education, the state of Texas chooses to dictate standards without providing financial support to meet the requirements. When will Texas support public libraries? Re-funding the Loan Star program would be a good step in the right direction ...
Comments and Suggestions: I agree with changes.
Comments and Suggestions: I think there should be changes in section 8, for libraries serving a population of 5,000 or fewer. These increases are too much for small communities to attain. There should be some kind of exemption or decreases in this section. This is going to effect a lot of libraries in Texas. Most of Texas is rural communities, and I think this is very directive and catastrophic towards low income families in rural communities, as the library is the only connection in rural Texas to communicate by fax, internet for a lot of low income families. Worst case scenario, we don't get accredited. Then rural libraries can't rely on grants,discount on e-rate, which most heavily rely on. Then libraries aren't able to maintain expenses for library, then the ultimate effect would be closures on a state wide basis. Which conflicts with the ACCREDITATION PRINCIPLES. "ANY NEW MINIMUM CRITERIA SHOULD BE SET TO INCLUDE ABOUT 95 PERCENT OF THE CURRENT MEMBERS" "NEW MINIMUM CRITERIA THAT EXCLUDES MORE THAT 10 PERCENT OF THE CURRENT MEMBERS WOULD SEEM EXCESSIVE" I think libraries serving a population of 5,000 or fewer account for more than 10 percent. Where would i find this information? But from the feedback I am hearing from different counties, most of rural libraries are looking at closure. Or at least this is how local governments are going to handle this change, if it takes effect.
Comments and Suggestions: great changes made.
Comments and Suggestions: For those of us who struggle with the one item per capita, the change to 15 percent of local expenditures is most welcomed.
Comments and Suggestions: This takes away local control of the collection. 1 % is not a large number, it may make it difficult for small libraries to meet the criteria. It could keep someone from replacing the classics due to copyright dates. Many libraries hold special collections that may have older copyright dates. I have the collection of the person who donated the funds to build the library with copyright dates in the late 1800's and early 1900's. It skews the average age of my collection. I would rethink this criteria and perhaps not include it.
Comments and Suggestions: I'm glad to see Item C finally added. Personally, I think one of the reasons libraries don't weedis so they can have their set amount of books needed to meet accreditation requirements. I think weeding is soooo important and weed informally almost daily and for sure weekly. Our shelves are less full but our materials are newer, get more circulation, we are being viewed as having the new books vs. having nothing that's relevant. I can understand the points made for smaller libraries where 1% might be good enough. For larger libraries (I'm 50,001-100,000), I think the 1% criteria should be way higher. Should I not weed to please the accreditation folks or should I weed to get new materials and make our library a more relevant, vibrant place? I choose the latter and worry about accreditation later. If there could be an either/or situation for this one....such as have 5/10/15% of collection published in last five years or have one item per capita..I would opt for the % of collection because I think that's more important, will drive more folks to see us, etc. The books I have on the shelves to meet current accrediation standards aren't moving. Perhaps libraries will find it easier to weed when there's not as many books to go through. I will never be able to spend 15% per capita on library materials. My governing authority doesn't love us that much. In sum: increase percentage of collection on C and make it an 'or' between B and C. Will do wonders to update and make libraries more relevant---I've seen a difference here when clearing out dusty books.
Comments and Suggestions: (8) Our tiny city has less than 2,000 people. We will never grow to 5,000 because other cities are all around us. Couldn't there be a library serving a population of 2,500 or fewer persons?
Comments and Suggestions: The definition of a professional librarian discriminates against libraries supported by school districts. The populations assigned to the school districts are out of proportion and the librarians employed by the school district are highly qualified to conduct all functions of the library, both for the students and the public. Since the school district is the main support for the public library, it should not be discriminated against for having a Master degree librarian with 25 years of experience who received a degree from a non-ALA accredited university.
Comments and Suggestions: Section (8) I think addition of item (c) is important. Would like clarification to exclude special collections, as geneology, Texas collection, etc. Clarify whether requirement is for total collection, as in both fiction and non-fiction. Also clarify if position of Library Director can be FTE hours, as in total hrs must be equivalent to 20 per week (Can combine hours of two people, as in a professional librarian working less than 20 hours, plus a Library Director working less than 20 hours.)
Comments and Suggestions: Sections B, specifying % of operating budget spent on materials, is too high a value. Please revaluate this number. Currently it is set at 25% and a review of the 2012 statistical data indicates that the criteria is being ignored because very few libraries meet that threshold. 15% will be met by only 24 of the 564 libraries (using the 2012 data set). 10% would be met by 330 libraries. Another commenter suggested an or pairing with another calculation - perhaps a minimum value for per capita for materials. Thank you.
Comments and Suggestions: Previously commented on % of budget expended upon materials and my comment reflected a misreading of this criteria. There are two alternatives - 1 item per capita & 15% of budget spent on materials. So, now I support the criteria in section B. 1 item per capita is a lax standard but OK as a minimum. IF that can't be met, then 15% of budget seems like a necessary, aggressive budget approach to strive towards 1 item per capita. Sorry for any confusion I introduced.
Comments and Suggestions: For libraries serving populations fewer than 5000, ALL the libraries that are potentially impacted by rule 1.74 are also potentially impacted by rule 1.81, because of the wording "whichever is greater". In 2019, 2020, and 2021 a per capita expenditure of $3.85 for a population of 5000 or fewer would give $19,250 or less, so the greater figure $21,000 applies, regardless of how small the population is. In 2022, 2023, and 2024 a per capita expenditure of $3.92 for a population of 5000 or fewer would give $19,600 or less, so the greater figure $24,000 applies, regardless of how small the population is. (For 2016, 2017, and 2018 the break-even population is 4774. Under the previous standards, for 2013, 2014, and 2015, the break-even population was 2878.)
The wording "local per capita expenditures or minimum total local expenditures, whichever is greater" should also be used for libraries serving 5001 - 10,000, since libraries with populations 5001 - 5700 are potentially impacted by the increased minimum total local expenditure in rule 1.74. In 2019, 2020, and 2021 the minimum total local expenditure of $21,000 is greater than a per capita expenditure of $4.05 for a population of 5,075 or fewer. In 2022, 2023, and 2024 the minimum total local expenditure of $24,000 is greater than a per capita expenditure of $4.21 for a population of 5,700 or fewer.
Comments and Suggestions: Maybe the wording should specify "professional librarian as defined by the American Library Association," leaving the meaning to change re 5th-year-degree, etc., separately without requiring re-wording in the standards.
Comments and Suggestions: Is "membership in the state library system" the same thing as Public Library Accreditation in the state of Texas? If so, it would be helpful to have the dual terminology explained in this document. If not, b. might need read something like "The following are the minimum requirements for [delete "membership in the state library system:"] [insert Public Library Accreditation in the state of Texas:"].
Maybe adding a terminology section to this document would be helpful. It would be especially helpful to have a definition of “quality” since it seems that providing quality libraries and library services is the purpose of setting accreditation standards.
(C) needs clarification. An item can be “published” in the last 5 years but originally released many years earlier. If the objective is to replace older items, regardless of copyright date, then the wording will work but remains vague. If the objective is to get newer titles into libraries, then maybe “copyrighted” in the last 5 years is more appropriate. For a few years, at least, simply increasing the eBook collection by an amount equal to 1% of total items in the collection could easily result in meeting this standard as worded, since cataloged eBooks count as items and since many eBooks have been published in the last 5 years. Often, though, the items have been recently published in a new format although the content remains more than 5 years old.
Is the intention of (C) to assure that all public libraries have at least a certain amount of current literature? of current non-fiction? of newer items, not necessarily newer titles or content? a collection that is both current and relevant?
If a library’s collection is to reflect the wants and needs of its community, it doesn’t make sense for the State to set standards relative to the collection’s content balance. Instead TSLAC / Library Development should strive to provide, annually, consulting and training that will help public library personnel assure that their collection is appropriately balanced according to the local community. That assistance should also address the issues related to accepting and considering donated items since donations can sometimes be the reason that a collection is not as current as what would be appropriate for the community.
Could the intention of this requirement be achieved by adding the option of withdrawing at least 1% of titles published over five years ago? It seems that many libraries (all sizes) are more in need of encouragement to weed than to purchase. With so many classics available as eBooks it seems that many libraries that offer their cardholders access to eBooks could meet a 1% requirement simply by rethinking the number of classics kept on their shelves. On the other hand, knowing that some smaller libraries insist on holding on to items in order meet the per capita requirement, it’s possible that adding that option would not help them.
It would help to use the term “FTEs (full-time equivalents)” for each first-time use in (F) since these standards are the concern of Board Members, government employees, elected officials as well as library personnel. This would keep readers from separating the term “equivalent” from the rest of the phrase and mis-interpreting the meaning.
Confusion caused by “(E) …; and (F) …” might be reduced by changing the wording to add, at the end of (F) something like, “in addition to the library director” if that’s the intention of those two requirements. If not, the vagueness needs to be addressed in each.
Comments on §1.82 Accreditation Based on Current Operating Budget
No comments submitted.
Comments on §1.83 Other Requirements
Comments and Suggestions: Why remove the possibility of a manual catalog as a viable option?????!!
Comments and Suggestions: S1.83 (5) should not be amended because poorer populations will not have electronic access capabilities, and the manual catalog will help save monies.
Comments and Suggestions: The ILL requirement is going to be tricky to enforce since TSLAC has now made it difficult, at best, for the smaller libraries.
Comments and Suggestions: Proof of Library Director's continuing education should have to be submitted to TSLAC.
Comments and Suggestions: Will all libraries be given a free website by the state library (i.e. Plinkitt) or will the cost fall on each individual library to maintain? (Domain name, maintenance, etc.).
Comments and Suggestions: Having a website is not sufficient. The website needs to be updated regularly and maybe under the control of the library. I just visited a website that shows a director who left the library 2-3 years ago. I also hear from a lot of libraries that they can't make any changes and updating is a low priority for the county/city. Policies are, I think, only mentioned in relation to ILL. Consider adding that the library has other polices (circulation, Internet, etc.) and those policies are available to the public and are reviewed at least every year or two years. Similar to the weeding requirement--the policies are not very useful if they are never reviewed.
Comments and Suggestions: I agree with these changes.
Comments and Suggestions: Many rural public libraries are staffed by people with little or no technical expertise. How is such a library going to establish and maintain a viable website?
Comments and Suggestions: I too would not eliminate the option of a manual catalog. Most electronic catalogs are superior and as much as I would encourage implementation, I think a manual paper catalog can still function adequately in a small library.
A web presence is important even without a lot of interactivity. A series of web pages could be provided very economically and without much technical expertise.
Comments and Suggestions: (3) too vague--a sign at the help desk? posted electronically?
Comments and Suggestions: Perhaps we should move to a standard where the number of public Internet computers available is based on the population served. One public Internet computer in a library would not likely be adequate for any but the tiniest libraries, and the standard as written allows larger libraries to meet requirements with extremely inadequate public Internet access.
Comments and Suggestions: I agree with changes.
Comments and Suggestions: As the library director in a small library, I am concerned about the ILL requirement and the website requirement. Since TSLAC's huge finding hit a few years ago, we have had nothing but trouble with ILL. With regard to the website requirement, both cost and know-how will be an issue for many small libraries.
Comments and Suggestions: good changes
Comments and Suggestions: When changes are made to the accreditation standards, I wish they would consider not requiring small libraries to offer inter library loan. We have never had more than 10 or 12 patrons ask us to borrow books on their behalf and if I told them they had to pay the postage, they wouldnt want the book ( most of patrons using this are our senior citizens). Paying $2200 or more for courier service seems out of line, to serve 10 or 12 people. Since we are a school/ community library, I am the only full time staff member during the day and my responsibities lie with the school during this time. I have one part time assistant in the evenings. I don't feel like we have the staff time or the funds to invest in the process.
We have had many more requests for ebooks the past year than anything else and have used our funds to pay for this service. Also, we have our largest attendance and circulation during our summer reading program and I do not want to cut funding to this program.
Comments and Suggestions: (6) It is vital to our library that we have continuing education and consulting available to us!!! Please don't take away free training. Clarification from TSLAC: The Regional Library Systems assisted libraries in developing their long range plans, per this rule. The language is being updated to reflect loss of those Systems. Continuing Education and Consulting is still available to all Texas public libraries, regardless of accreditation status.
Comments and Suggestions: Does a 3 year technology plan that is required for e-rate fulfill the requirement for the technology element in a long range plan? Response from TSLAC: Yes, a technology plan could fulfill the technology element required in a long-range plan.
Comments and Suggestions: It was stated in the webinar that a library's web page on a city or county website could satisfy the requirement for a website. In that case, perhaps the requirement should be for a web presence rather than a website … and perhaps it should specify whether any particular information is required, such as location, hours, and contact information.
Comments and Suggestions: Would like to see some change in the ILL requirement. Small libraries have little need for this, but could make an ILL arrangement with a neighboring library if needed.
Comments and Suggestions: Why not title this entire document simply "Minimum Standards for Public Library Accreditation in Texas" since those who remember systems have a different concept of the State Library System? If this happens, then reference to "the system" and "the State Library System" throughout the document will need to be changed.
Does (2) mean that the staff’s photocopier must have Internet access (meaning more-current technology)?
If participation in ILL is a requirement under (3), then ILL isn't, in itself, a benefit of accreditation. Access to the required software and related training plus the possibility of subscribing to the courier service (if the library's budget can cover that additional expense) are the ILL-related benefits to accreditation.
The re-wording of (5) is awkward. How about “…that is electronically searchable by author, title, and subject, at a minimum” or maybe “…that is searchable online by at least author, title, and subject.”
In (6) should “Governing Board” be changed and, if so, to what? Governing Board or Local Government Governing Body? Governing or Advisory Board? Other?
An Excel spreadsheet is searchable electronically. If such a spreadsheet is made available to the public and has entries for author, title, and subject, it seems that that would satisfy the requirement for an electronically searchable catalog. If not, perhaps the wording needs to be more specific to what the Task Force is expecting.
What good does it do to have a long-range plan if there is no requirement to follow or meet it? Does TSLAC staff have time to review and critique every LRP or otherwise verify that those plans actually exist? Similarly, why dictate CE requirements for the library director and then state that the director must maintain appropriate documentation? If failure to meet the requirement would not be obvious, why include the standard? If the standard is intended to assure that the library director is allowed and encouraged to keep training current, why not require copies of the documentation via email, fax or mail, at the time that the annual report is submitted?
Comments on §1.84 Professional Librarian
Comments and Suggestions: Does ALA even accredit the "fifth year degree in librarianship" any more? I'm not sure but I don't think so. I tried to find one but couldn't.
Comments and Suggestions: It seems to me that libraries serving 10,001-25,000 persons should also need a "professional" librarian. Since these libraries do not have to be open more than 30 hours a week, perhaps they should be required to have .75 equivalent professional librarian.
Comments and Suggestions: As a small County library with funds as we all know an issue. Having a MLS librarian is hard to find on the budget that the County pays. The director runs both libraries and there is no extra funds for staffing. What exactly does equivalent professional librarian mean. No MLS but almost 18 years of library experience and hundreds of hours with HALS training. Does this person qualify as an equivalent librarian??
Clarification from TSLAC: The requirement for a professional librarian is in §1.81. It is not required for libraries that have an assigned population of less than 25,001. Per §1.84, a professional librarian is “a person holding either a fifth year degree in librarianship from a program accredited by the American Library Association or a master's degree in library or information science from a program accredited by the American Library Association or a higher credential from a library school offering an American Library Association-approved program in library or information science.”
Comments and Suggestions: Maybe the wording should specify "professional librarian as defined by the American Library Association," leaving the meaning to change re 5th-year-degree, etc., separately without requiring re-wording in the standards.
Is a BS in Library Science from an ALA-accredited program considered “a higher credential”? That term is vague.
This statement, “Upon the written request of persons holding degrees in library or information science from schools outside the United States or Canada, the state librarian may certify them as professional librarians if their program of study is deemed comparable to that of a library school accredited by the American Library Association.” seems to discriminate unfairly against individuals who earned Library Science degrees in the US but at schools that are not accredited by ALA. If the state librarian uses a specific standard to deem a program of study to be comparable to that of an ALA-accredited program, that standard should be included in this section instead of making the decision seem potentially arbitrary.
Comments on §1.85 Annual Report
Comments and Suggestions: I have read all and have no additional comments. Thanks to the committee for taking this on!
Comments and Suggestions: What benefits does a library receive from the state library? An annual report seems a waste of time for all of the rules and regulations just to be accredited.
Comments and Suggestions: An annual report is of great value just for the comparative statistics it makes available.
Comments and Suggestions: I am in total support of these recommended changes.
Comments and Suggestions: Does “disqualified” mean no chance of provisional or probational status?
Comments and Suggestions: I do not feel that most of these requirements, especially for the money areas, are realistic for small and rural libraries