This is the accessible text file for GAO report number GAO-07-871R 
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June 12, 2007: 

The Honorable James H. Billington: 
Librarian of Congress: 

Subject: Talking Books for the Blind: 

Dear Dr. Billington, 

The National Library Service for the Blind and Physically Handicapped 
(NLS), a part of the Library of Congress, operates a free national 
talking (audio) book program for qualified blind, visually impaired, or 
physically disabled residents of the United States and its territories, 
as well as qualified U.S. citizens residing abroad. NLS produces and 
distributes analog cassette players and talking books and periodicals 
recorded on audio cassettes to approximately 434,000 individual 
subscribers and 33,000 institutions through a network of 132 
participating libraries and the U.S. Postal Service (USPS). 

In the 1990s, NLS recognized that analog audio cassette technology was 
becoming outdated and nearing the end of its useful life and initiated 
efforts to plan for a new, digitally based talking book system. NLS 
analyzed three alternatives for the system--CD, hard drive, and flash 
based media--and chose to award a contract for the development of a 
digital talking book system based on flash memory media.[Footnote 1] 
The development phase is now nearing completion, and NLS is planning to 
award the manufacturing contract for the digital talking book system in 
August 2007. Figure 1 shows the prototype of the standard digital 
talking book player, the NLS talking book flash memory cartridge, and 
the mailing container. 

Figure 1: Prototype of the NLS Talking Book Player System: 

[See PDF for image] 

Source: National Library Service. 

[End of figure] 

Under U.S. copyright law, NLS is authorized to reproduce and distribute 
talking books without copyright infringement as long as they are 
produced in a specialized format exclusively for use by blind or other 
persons with disabilities.[Footnote 2] The standard describing the 
specialized format for digital talking books is maintained by the 
Digital Audio-Based Information System (DAISY) consortium--an 
international organization established to develop specifications and 
tools for digital talking books--and accordingly is commonly known as 
the Daisy standard.[Footnote 3] 

The digital talking book project is a significant system development 
and acquisition investment. NLS estimates the 5-year (2007-2011) cost 
of the program, including the player and media acquisition, to be about 
$174 million. Over this same time period, NLS plans to continue the 
cassette-based talking book program, whose cost is estimated at about 
$44 million. The 5-year cost of the combined digital talking book and 
cassette programs is about $218 million. 

The Chairman and Ranking Member of the House Committee on 
Appropriations asked us to review NLS planning and management of its 
digital talking book development and acquisition project. Specifically, 
our objectives were to determine to what extent NLS (1) performed 
sufficient analyses to select technologies for the next generation of 
the talking book system and (2) effectively managed the development of 
the selected digital talking book technology and mode of distribution. 

To address our first objective, we reviewed the program's legislative 
authority, as well as supporting copyright law;[Footnote 4] reviewed 
relevant federal acquisition and system development guidance, including 
that of the Library of Congress; evaluated NLS's analysis of 
alternatives, life-cycle cost estimates and methodologies, cost to 
transition from the current to the new system, cost/benefit analyses, 
and other project management plans and procedures associated with the 
talking book program; reviewed and assessed NLS data used to develop 
the digital talking book player, media, duplication process, and 
distribution system; estimated the cost to USPS for delivery of talking 
book players and media; conducted interviews with officials from the 
Library of Congress's National Library Service for the Blind and 
Physically Handicapped and Information Technology Services, the 
program's contractors, USPS, the organization of Chief Officers of 
State Library Agencies, and the District of Columbia Public Library, as 
well as representatives from interest groups for blind and disabled 
persons; and conducted interviews with major organizations (eight 
foreign and two U.S.) that provide audio book services for the blind 
and reviewed their service structures and technologies. 

To address our second objective, we evaluated NLS processes for 
requirements development, risk management, and quality assurance, as 
well as system progress reports, contractor deliverables, and other 
documentation associated with the talking book program in the light of 
guidance and industry standards; assessed the validity of technology 
test plans, protocols, and results; conducted interviews with library 
officials; and reviewed the 2006 assessment of the digital talking book 
program performed by the library's Office of the Inspector General. We 
performed our work at NLS offices, Library of Congress headquarters, 
USPS headquarters, the District of Columbia Public Library in 
Washington, D.C., and the contractor's headquarters in Columbus, Ohio, 
from September 2006 to February 2007 in accordance with generally 
accepted government auditing standards. 

On March 8, 2007, we briefed the requesters' staff on the results of 
our study. In addition, we provided you with the briefing slides, which 
contain the detailed support for our recommendations. The purpose of 
this report is to summarize those results and transmit our 
recommendations to you. 

In summary, NLS analyzed various alternatives for the digital talking 
book program starting in 2000, but the analyses did not have the rigor 
recommended by library guidance and government and industry best 
practices[Footnote 5] to ensure that new assets are acquired through 
sound decision making. To its credit, NLS conducted market research and 
consulted with experts and stakeholders, including representatives from 
international organizations with similar programs, domestic groups 
representing people who are blind and physically disabled, and 
manufacturers. The agency identified and discussed numerous alternative 
technologies (including CD, flash memory, and miniature hard drives) 
and distribution mechanisms (such as Internet delivery via broadband 
channels and cable television channels). However, the agency's analysis 
of selected alternatives focused solely on the technology medium and 
the player and did not broadly consider the entire program and its 
underlying processes: 

 NLS did not consider alternative ways to distribute players to the 
subscribers--such as direct shipment from the manufacturer to the 
patron--that could be less costly than the current process. 

 NLS did not consider using commercial players designed specifically 
for people who are blind and physically disabled which include features 
such as tactile indicators and audio prompts and are compliant with the 
Daisy standard. For example, the agency had previously rejected 
commercial CD players based on its 2000 analysis, even though similar 
programs in other countries rely on such players to serve their 
subscribers. Figure 2 shows Victor Reader ClassicX, one of many 
commercial Daisy CD players used by blind and visually impaired talking 
book readers around the world. In addition, NLS did not consider using 
commercial services to distribute talking books to subscribers. 

Figure 2: Victor Reader Classicx Commercial Daisy CD Talking Book 
Player from HumanWare: 

[See PDF for image] 

Source: HumanWare Canada,  2007. 

[End of figure] 

 NLS did not fully analyze the initial acquisition and life-cycle 
costs of each alternative--nor did it update its 2000 analysis of the 
CD and flash alternatives--as recommended by best practices. For 
example, the analysis stated that one-way mailing of CDs to 
subscribers--an approach that could significantly reduce the $40 
million that NLS spends annually on mailing costs--would require highly 
automated equipment and technical staff to support it and concluded 
that few network libraries could provide such an environment. Because 
the analysis assumed that one-way mailing would continue to rely on 
network libraries for distribution (essentially mirroring the current 
distribution approach), NLS did not consider, for example, whether the 
use of commercial CD duplicating services or a centralized CD copying 
center that directly ships the media to the patron would be feasible. 

 NLS did not provide documentation to support key technical 
conclusions, such as the advantages and disadvantages cited for each 
alternative. For example, its conclusion that repairs to CD and hard- 
drive-based players would be "relatively expensive for commercial 
repairers to perform" was not supported by technical studies or 
analysis. 

Without a rigorous analysis of alternatives, NLS, the Congress, and the 
public will have limited assurance that the selected solution is the 
optimal one for delivering audio content to people who are blind and 
physically disabled, and NLS may be missing an opportunity to select a 
solution that costs less and serves its subscribers better. 

Furthermore, NLS developed several, but not all, of the acquisition 
plans and processes recommended by best practices. For example, the 
agency developed functional requirements, a program schedule, and 
testing plans. However, it did not develop a concept of operations 
describing how the talking book system is to operate; a project 
management plan including information on project organization, 
constraints, and assumptions; or a risk management plan identifying and 
prioritizing risks to the project. According to generally accepted 
business practices for acquiring and developing a system,[Footnote 6] 
such plans and procedures can give NLS the guidance and framework 
necessary to execute, monitor, and control the talking book program in 
a way that meets the needs of its users and other stakeholders. Without 
complete plans and processes to guide the modernization, the agency 
faces risks to the project's cost, schedule, and performance. 

The weaknesses in NLS's approach existed, in part, because NLS was not 
required to adhere to the Library of Congress's system development 
guidance, which would have provided a structure for performing an 
alternatives analysis and managing the project. Furthermore, the 
library's Chief Information Officer does not have the authority to 
provide oversight of the project. 

To ensure that the best solution is selected and effectively delivered 
to talking book subscribers, we recommend that you require the Director 
of NLS to take the following two actions: 

 Develop and document analyses of alternatives, including technologies 
and distribution options, before continuing further work on the talking 
book modernization project. At a minimum, these analyses should (1) 
identify and consider alternatives for all aspects of the talking book 
program, (2) consider the use of commercial products and services, (3) 
fully analyze the initial acquisition and life-cycle costs of each 
alternative, (4) provide support for key technical conclusions, and (5) 
be consistent with library guidance. 

 Strengthen NLS's capabilities for modernizing the talking book 
program by developing a concept of operations and project management 
and risk management plans consistent with the library's guidance and 
industry best practices. 

We also recommend that you require the Chief Information Officer to 
oversee these efforts and ensure that they are accomplished in 
accordance with library guidance. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, you concurred with our 
recommendations and described actions to address issues cited in the 
draft report, particularly in the areas of analyses of technologies and 
distribution options, NLS's capabilities for modernizing the talking 
book program, and oversight by the Chief Information Officer. 

You also noted that the digital talking book program has been in the 
planning stage for nearly a decade and that the blind community has 
high expectations for its implementation. You stated that the analyses 
and planned actions we recommended to strengthen NLS acquisition 
management can be carried out concurrently with the current acquisition 
schedule for the talking book system and the library's fiscal year 2008 
funding request. 

We concur with the library's approach and agree that the necessary 
analyses and management actions to strengthen the digital talking book 
program could be performed concurrently with the tasks required for the 
initial delivery of the talking book system. These actions, if 
implemented as described, should ensure that NLS delivers a digital 
talking book solution that best serves the interests of both the 
program's patrons as well as taxpayers. Your written comments are 
reprinted in enclosure I. 

We are sending copies of this report to the Chairmen and Ranking 
Minority Members of Senate and House committees that have authorization 
and oversight responsibilities for the Library of Congress. We will 
also make copies available to others upon request. In addition, the 
report will be available at no charge on the GAO Web site at 
www.gao.gov. 

Should you or your staff have any questions on matters contained in 
this report, please contact me at (202) 512-6240 or by e-mail at 
koontzl@gao.gov. Key contributions to this report were made by Mirko J. 
Dolak, Assistant Director; Nabajyoti Barkakati; Timothy E. Case; 
Barbara S. Collier; Heather A. Collins; Neil J. Doherty; Mustafa S. 
Hassan; John C. Martin; and Amos A. Tevelow. 

Sincerely yours, 

Signed by: 

Linda D. Koontz: 
Director, Information Management Issues: 

[End of section] 

Enclosure I: Comments from the Library of Congress: 

The Librarian Of Congress: 

June 1, 2007: 

Dear Ms. Koontz: 

Thank you for your letter of May 23 summarizing the results of GAO's 
study of the Library's acquisition of a digital talking book system. We 
appreciate the work and thought that went into your report. 

I have discussed your recommendations with Dr. Deanna Marcum, Associate 
Librarian for Library Services, the senior Library official responsible 
for the National Library Service for the Blind and Physically 
Handicapped (NLS). The Library's response to the recommendations 
follows. 

Require the Director of NLS to take the following actions: 

* Develop and document analyses including technologies and distribution 
options before continuing further work on the talking books 
modernization project. At a minimum, these analyses should (1) identify 
and consider alternatives for all aspects of the talking books program, 
(2) consider the use of commercial products and services, (3) fully 
analyze the initial acquisition and life-cycle costs of each 
alternative, (4) provide support for key technical conclusions, and (5) 
be consistent with Library guidance. 

The Library concurs. Dr. Marcum, after consultation with the Chief 
Information Officer and the Chief Operating Officer, has asked Ruth 
Scovill, the system designer for the Library's largest technology 
project to date (creation of the digital preservation system for the 
National Audiovisual Conservation Center) to work with NLS staff and 
contractors, as required, to develop the analyses called for in your 
report. Ms. Scovill will be on site at NLS for the next few months, and 
will report directly to Dr. Marcum. 

NLS received the "Development of Life Cycle Cost Model for DTB's, Draft 
Report" from ManTech Advanced Systems International since the receipt 
of GAO's preliminary report, and we enclose it with this letter. It is 
only a partial response to your recommendation, as it sets forth the 
life cycle costs of the flash-technology-based program. We understand 
that the same kind of analysis needs to be carried out for other 
technological alternatives. 

* Strengthen NLS's capabilities for modernizing the talking books 
program by developing a concept of operations and project management 
and risk management plans consistent with the Library's guidance and 
industry best practices. 

The Library concurs. NLS has agreed to develop formal concept of 
operations, project management, and risk management plans. 

NLS currently uses a combination of industry-recognized tools and 
management procedures to effectively control the project's cost, 
schedule, and corresponding risks. Microsoft Project is used to 
compile, coordinate, and track tasks, time schedules, and costs for 
more than thirty sub-projects of the digital program. A combination of 
Microsoft Project and principles from the Project Management Body of 
Knowledge Guide is used to manage contractor tasks associated with the 
design and development of the DTB player, cartridge, and container. 
Project and cost changes are managed through a controlled NLS process 
that includes documenting change proposals and associated costs, 
obtaining approval from the Digital Audio Development Committee (the 
NLS management group for the project), and adjusting schedules, costs, 
and program budget for approved changes. The Library will direct Ms. 
Scovill to examine all of these procedures and to advise on how they 
can be improved. 

* We are also recommending that you require the Chief Information 
Officer to oversee these efforts and ensure that they are accomplished 
consistent with Library guidance. 

The Library concurs. The Digital Talking Books program will be reviewed 
by the Chief Information Officer. Dr. Marcum will ensure that the work 
of NLS is consistent with Library guidance. 

As you are keenly aware, the blind community, in particular, is eagerly 
awaiting the transition from audiocassettes to digital technology for 
the talking book program. We shall continue to work closely with that 
community, along with all of the groups that represent the blind and 
physically handicapped communities, to develop a system that provides 
superior service, while remaining alert to cost/benefits analyses. 

The Digital Talking Book program has been in the planning stage for 
nearly a decade, and the blind community has high expectations for its 
implementation. By making the analyses called for in the GAO report Ms. 
Scovill's highest priority, we expect to work quickly to resolve all of 
the outstanding issues. With four months remaining in the current 
fiscal year, we believe that the analyses can be done concurrently with 
the tasks promised for delivery in our FY 08 funding request. 

I shall make certain that any work done leading to implementation 
remains flexible enough to be modified by results of the additional 
analyses. We believe that the probable long-term solutions will be 
possible within the budget we have proposed for the Digital Talking 
Books program and that adjustments to the original plan can be 
accommodated. We are confident that the analyses need not unduly affect 
the timing of the overall program. But our goal is the same as GAO's: 
to make certain that government-provided services are of the highest 
quality to the user community at the least cost to the tax payers. 

Dr. Marcum will be pleased to follow up with any questions you have. 

Sincerely, 

Signed by: 

James H. Billington: 
The Librarian of Congress: 

Enclosure: 

Ms. Linda D. Koontz: 
Director, Information Management Issues: 
441 G Street, N.W., Room 4075: 
United States Government Accountability Office: 
Washington, DC 20548: 

[End of section] 

FOOTNOTES 

[1] Flash memory is used in flash drives, which permit storage and 
transfer of data between computers. 

[2] See 17 U.S.C.  121. 

[3] To protect copyrights, the Daisy standard addresses ways to encrypt 
and control access to the recorded content. 

[4] 2 U.S.C.  135a-135b and 17 U.S.C.  121, respectively. 

[5] Office of Management and Budget (OMB), Capital Planning Guide, 
Version 2.0: Supplement to Office of Management and Budget Circular A- 
11, Part 7: Planning, Budgeting, and Acquisition of Capital Assets 
(Washington, D.C.: June 2006); P2C2 Group, Inc., Federal Sector Report: 
Analyzing Alternatives for Federal Capital Investments (Washington, 
D.C.: October 2003); Department of Defense, Defense Acquisition 
Guidebook; the Institute of Electrical and Electronic Engineers (IEEE), 
1490-1998, A Guide to the Project Management Body of Knowledge, and 
1362-1998 (New York, N.Y.: 1998), IEEE Guide for Information 
Technology--System Definition--Concept of Operations Document (New 
York, N.Y.: 1998); Library of Congress, Information Technology 
Services, System Development Life Cycle Methodology, Version 2.0 (May 
2006) and Project Management Handbook (Washington, D.C.: November 
2006). 

[6] IEEE Std 12207.0-1996, Standard for Information Technology-- 
Software Life Cycle Processes (New York, N.Y.: 1996); IEEE Std 12207.1- 
1997, Standard for Information Technology--Software Life Cycle 
Processes--Life Cycle Data (New York, N.Y.: 1997); IEEE Std 12207.2- 
1997, Standard for Information Technology--Software Life Cycle 
Processes--Implementation Considerations (New York, N.Y.: 1997); and 
IEEE Std 1362-1998, IEEE Guide for Information Technology--System 
Definition--Concept of Operations Document (New York, N.Y.: 1998); 
Department of Defense, Defense Acquisition Guidebook; Library of 
Congress, Information Technology Services, System Development Life 
Cycle Methodology; Version 2.0 (May 2006) and Project Management 
Handbook (Washington, D.C.: November 2006).

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