Talking Books for the Blind (12-JUN-07, GAO-07-871R).
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outdated and nearing the end of its useful life and initiated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. 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. 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. 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. 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.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-871R
ACCNO: A70613
TITLE: Talking Books for the Blind
DATE: 06/12/2007
SUBJECT: Blindness
Books
Federal procurement
Libraries
Persons with disabilities
Procurement planning
Procurement practices
Program management
Systems analysis
Technology
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GAO-07-871R
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.^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.
^1 Flash memory is used in flash drives, which permit storage and transfer
of data between computers.
Figure 1: Prototype of the NLS Talking Book Player System
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.^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.^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.
^2 See 17 U.S.C. S 121.
^3 To protect copyrights, the Daisy standard addresses ways to encrypt and
control access to the recorded content.
To address our first objective, we reviewed the program's legislative
authority, as well as supporting copyright law;^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^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:
o 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.
o 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.
^4 2 U.S.C. SS 135a-135b and 17 U.S.C. S 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).
Figure 2: Victor Reader Classicx Commercial Daisy CD Talking Book Player
from HumanWare
Source: HumanWare Canada, (c) 2007.
o 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.
o 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,^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:
o 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.
o 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.
^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).
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
[email protected]. 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,
Linda D. Koontz
Director, Information Management Issues
Enclosure I: Comments from the Library of Congress
(310790)
*** End of document. ***