AD-A263 275 I I NillIlIIHhlllllllilIII! Government Publications Review, Vol. 18. pp. 435-450. 1991 0277-9390/91 $3.00 + 00 Printed in the USA. All rights reserved. - 1991 Pergamon Press plc . 1993 APR 23 0 IMPROVING THE DISSEMINATION OF UNITED STATES GOVERNMENT INFORMATION The Report of the Public Printer's Sales Publications Pricing Panel STUART M. FOSS* Chairman. Sales Publications Pricing Panel, U.S. Government Printing Office. Washington, DC 20401, USA to'lCE: This material may ne protected by opy2?ight law (Title 1? U.S. Codel 0 Abstract - The Government Printing Office's Sales of Publications Program was es- tablished by Congress to disseminate government information to the public at an eco- W nomical price. It is one of the few government programs that operates on a self- sustaining basis. In fact. the Sales Program has generated excess revenue that, by law, ('u -- fLn is returned to the Treasury. Several months ago. the Public Printer initiated a special study of the Sales Prograi as it relates to documents pricing and the distribution of OMM government information. The Pu';,.: Printer recently released the study group's final report. In this article, the chairman of the study group discusses the report's findings, Q = conclusions and recommendations. Eleven diverse issues were considered by the study I group in areas such as pricing, marketing, program administration, and appeals of dis- = puted prices. The report has three main themes: (a) the law that governs pricing for sales publications affords sufficient discretion to test alternative approaches to the cur- ) rent pricing formula; (b) because the sales prices of government books are based on their per unit cost. lower prices can be achieved by increasing sales volume; and (c) commercial book outlets constitute an untapped resource for the dissemination of gov- ernment information to the public and changes are needed to attract such private sector participation. 93 4 40 161 INTRODUCTION One of the principal avenues by which United States federal government infonnation reaches the public Is the Government Printing Office's (GPO) Sales of Publications Program (Sales Pro- gram) [1]. Under the management of the Superintendent of Documents, the Sales Program makes available to the public a wide variety of government publications, periodicals, and other E documents at prices that are set according to a formula contained in GPO's enabling statute- 20 Title 44 of the United States Code [2]. As of September 30, 1989, there were nearly 14,000 U separate titles in the Sales Program's inventory, 80 percent of which were priced at $15.00 Sor less. At present, government books and publications flow through the Sales Program to the public S(cid:127) either by mail order or across the counter at one of the 23 government bookstores operated by "(cid:127) ,(cid:127) GPO. There are few titles in the inventory that are seen by the public in commercial book- .,: stores. Since the government's book dealer discount policy does not fit industry practice, its publications are unattractive to private sector retail outlets 13]. *Stuan M. Foss is currently GPO's admlnis.ative law judge and serves as chairman of the GPO Board of Contract Appeals. In a federal career spanning 23 years. Mr. Foss has held Increasingly responsible positions with GPO and several other government agencies. Mr. Foss Is an attorney who has previously chaired two committees of the Ameri- lu1p 3 IIUT-ATLMMDI..A A~ppr"d PuUwl 435 5TA0d12 - ~Wdbutd formpt~u li r~m r1 436 S.M. FOSS In the nearly 100 years of the Sales Program's existence, two major issues have repeatedls surfaced. The first concerns pricing, and specifically focuses on the methodology employed to set prices. The second involves distribution, namely, finding better ways to market government publications and expand the number of outlets for government books and periodicals Both k- sues, however, spring from the same desire to increase the dissemination of government infor- mation by, among other things, lowering prices (on the theory that there is a direct correlation between prices and sales volume) and finding incentives for private sector bookstores to stock government publications. In November 1990, the Public Printer, Robert W. Houk. released the results of a five-month study on documents pricing, which recommended several alternatives for improving the meth- ods of pricing and distributing government publications sold to the public by GPO. The studN was conducted by a group of representatives from GPO, federal publishing agencies. and the library community-the GPO Sales Publications Pricing Panel (Panel) [4]. Public Printer Houk had ordered the study group to review GPO's pricing structure and devise options for reducing the prices and increasing the dissemindtion of government documents through the Sales Pro- gram [5]. The Panel saw its task as covering four broad issue areas: (a) pricing issues, (b) marketing issues; (c) pricing appeals issues; and (d) other program administration issues [6]. The Panel made several key findings, conclusions, and recommendations in its final report, including: "*T he current formula for pricing GPO sales publications achieves the purposes for which it was designed, namely, recovering the overall costs of the Sales Program while establishing prices that are commensurate with a wide variety of GPO sales publications. However, the statute gives the Public Printer flexibility to choose other pricing mechanisms, provided that the overall costs of the Sales Program are recovered. "*A n alternative way to set prices for book dealers based on the actual cost of distribution could attract private sector retail outlets for government publications. The Panel recommended. $ however, that its new approach first be tested on a pilot project basis. "*T he 25-percent limit on book dealer discounts in the statute is an obstacle to marketing gov- ernment publications through private sector bookstores, which expect discounts of not less 11 than 40 percent in accordance with current trade practice. Therefore, as an alternative to al- lowing book dealer prices to be set on the basis of actual cost of distribution, the Panel rec- ommended a legislative change that would allow the Public Printer to establish a discount .- ' policy commensurate with the conditions and practice in the industry on a pilot project basis. "*G PO's traditional policy of selling excess publications as scrap is not a legal requirement, but is based on a previous management business decision. Therefore, the Public Printer should -, permit appropriate overstocks to be sold to book dealers and other quantity purchasers as surplus property. "• No formal pricing appeals procedure needs to be established at this time because agency/ publishers are generally satisfied with the pricing structure applied to government publica- tions sold through the Sales Program. [t "*A n ad hoc working group of the Public Printer's Interagency Council on Printing and Publica- El tions Services was a potential advisory body for the Sales Program, and the Panel recom- mended that it be given permanent status for that purpose. The Panel also recommended that the Council examine the government's dual distribution policy; i.e., where publications in the Sales Program's inventory are also available from the publishing agencies free-of-charge. The Panel's supporting data and reasoning were set forth at length in the 54 pages and 15 )ides appendices of the final report [7]. While it is not the intent of this article to examine the final or Dissemination of U.S. government information 437 report in detail, the scope and extent of the Panel's work will be evident even from this brief discussion of its findings and conclusions. PRICING FORMULA ISSUES The current formula for pricing GPO sales publications achieves the purposes for which it was designed, namely, recovering the overall costs of the Sales Program while establishing prices that are commen- surate with a wide variety of GPO sales publications. However, the statute gives the Public Printer flexibility to choose other pricing mech- anisms. provided that the overall costs of the Sales Program are re- covered. The pricing formula applied by GPO to the government publications that it offers for sale is based on statute. Section 1708 of Title 44 of the United States Code requires that the sales prices of government publications be based on the "cost as determined by the Public Printer plus 50 percent" [8]. Although GPO has used different pricing formulas over the years, all have had the same function-they have been designed to recover the total Sales Program costs; i.e., both the direct and indirect costs involved in the program (9]. As indicated by one of the Panel's predecessors, the 1976 Documents Distribution and Pricing Study Group (Study Group)- No precise or scientific data gave rise to any of the "formulas" or their revisions. They were instead merely a convenient administrative device for adjusting sales prices to assure revenues would exceed incremental costs. As costs began to overtake reve- fues, the "formula" was revised to yield greater revenues .... The names applied to these various percentages bore no real relationship to the cost factors involved. What was important was "the bottom line." whether revenue exceeded costs (10l. The Study Group also observed that the basis for all versions of the pricing formula was the premise that the Sales Program should be self-sustaining and all the incremental costs associ- ated with it should be recovered [1Il. Consequently, central to any formula adopted by GPO is that prices must recover the costs associated with the Sales Program so it can operate on a self-sustaining basis. This central concept, that the Sales Program must be self-sustaining, is what guides the traditional interpretation of 44 U.S.C. section 1708 [12]. Moreover, past ac- tions by GPO's congressional appropriations committees have forced the conclusion that being self-sustaining means more than breaking even [13]. Acting on this bottom line approach, GPO has foilowed a financial philosophy by which the total revenues from the Sales Program are expected to exceed the total costs. As a consequence, the function of any pricing formula has been to generate revenue to cover Sales Program costs. Even though pricing formulas are expected to produce income, this is not to say that estab- lishing prices for publications sold by GPO is solely an exercise in business or economic judg- ment. There are countervailing social and political considerations that must be factored into any pricing mechanism because the Sales Program is one of the major avenues for the dissemina- tion of government information to the pubjic. Indeed, Congress is acutely aware of this role of the Sales Program and has from time to time expressed its concern that, while publication prices should be adequate to recover costs, the pricing mechanism itself should not become an obsta- cle that would deprive the public of access to such information [14]. To guard against this danger, GPO has adopted a separate mechanism for selling small publications at a price com- mensurate with their size. The current pricing formula is comprised of four central components: (a) printing and bind- ing costs; (b) postage; (c) handling; and (d) the 50 percent markup required by 44 U.S.C. sec- limp, 438 S.M. FOSS tion 1708 [151. Generally, all components are estimated prior to actual printing and publi,:ation. and a sales price is assigned at that time. All computations of the sales price are rounded in accordance with a fixed formula. The small publications problem has been addressed b,, GPO., adoption of a formula in which handling charges are assessed according to a douments size in square inches [16]. Similarly, in recent years. postage has been treated like all other cosr\ sub- ject to 44 U.S.C. section 1708, and is included within the range of costs subject to the 50 percent markup [17]. However, notwithstanding any fine tuning, the four components of the formula itself have remained unchanged. Finally, although a minimum price of $1 00 has been placed on Sales Program publications, there has been no maximum price. The Panel's test of the validity of the current pricing formula-i e.. does, it fairl% refle,:t costs, and does it discriminate among larger and smaller publications -- as based on a represen- tative sample of 115 items selected at random from the sales inventor. The sample , ealu- ated against criteria developed by the Panel that were intended to relate the publication's price to its: (a) size: (b) complexity; (c) quality of materials: (d) contribution to the recoverý of total Sales Program costs; and (e) prospective life cycle. Using the Documents Standard Pricing Scales. the Panel compared the sample publications against this five-part yardstick and found 4 that the application of the current pricing formula resulted in prices that adequately reflected the differences between them [18]. In addition to running a sample test, the Panel also looked at the sales prices of all items in GPO's inventory as of September 30. 1989. On that date, the inventory contained approxi- mately 14,000 titles, 12,000 of which were priced at $15.-0W or les-. This 12,000-title figure included 2,500 publications with the minimum price of SI.00, and more than 7,000 titles -ell- ing for $3.00 or under. Since the average handling cost is S4.51. and some 7.000 publicatisnos are priced at $3.00 or less, it was obvious to the Panel that half of the titles in the itnvntor\ are priced below the average handling cost. Thus, the Panel had to agree that there is a surface merit to arguments made by some critics that the larger publications are bearing a disproportion- ate share of the Sales Program's costs. It noted, however, that this situation exists as a result of a conscious decision on the part of GPO management, consistent with the wishes of Congress. to maintain low selling prices for smaller government publications [19]. Based on its study, the Panel concluded that the current pricing formula and the scales that implement it satisfied not only the evaluation criteria it used. but also performed their main functions on behalf of the Sales Program-to recover all of the costs of the Sales Program and keep it on a self-sustaining basis while maintaining a reasonable pricing structure for small pub- lications. Although there were some individual pricing variations, they were not significant in the Panel's view, and the formula appears to achieve its principal purposes on a consistent basis. As a consequence, insofar as the current four-part formula satisfies the legal require- ments of 44 U.S.C. section 1708. and offers a sound foundation for making pricing decisions within the context of the Sales Program, the Panel concluded that it is a valid approach by which the Public Printer can meet his responsibilities under the law. However, the Panel did feel constrained to add that, while it found the present pricing for- mula satisfactory for the purposes of the Sales Program and the law, this should not be taken as an unqualified endorsement of the current approach. Indeed, the Panel observed that the history of pricing at GPO is replete with evidence that the Public Printer has the flexibility to try other approaches and formulas as long as the overall costs of the Sales Program are recovered. Thus. the Public Printer could exercise his s:atutory discretion to develop a new formula with differ- ent components. However, it was not the Panel's purpose, nor was it within its charter, to identify all of the pricing options available to the Public Printer that would meet the require- ments of 44 U.S.C. section 1708. Tnstead, the Panel observed that the current pricing formula is merely one of many possible choices, but it is by no means the only one. Dissemination of U.S. government information 439 To further the goal of attracting private sector retail outlets for Gov- emnment publications, GPO could institute an alternative pricing mech- anism for book dealers based on the actual cost of distribution, instead of asking Congress to provide higher discounts by statute. However, this new approach should first be tested on a pilot project basis. The pricing statute-44 U.S.C. section 1708-only allows the Public Printer to offer a dis- count not to exceed 25 percent to book dealers and quantity purchasers (20]. This low discount rate is a major reason that the bookstore chains have closed their doors to the publications offered by GPO; i.e., the statutory 25 percent discount is out of step with current commercial practice in the industry where private sector bookstores expect discounts of not less than 40 percent. As a consequence, the statutory discount does not provide enough incentive to book dealers to stock government publications. The Panel realized that the current pricing formula conforms to the traditional pricing philos- ophy at GPO, which is predicated on the basic assumption that the Sales Program is a retail operation. In other words, the pricing formulas used by GPO, now and in the past, have nor- mally ignored publications that are, in fact, sold as wholesale items; rather, most publications are priced as if they were individual sales by mail (21]. Thus, the Panel believed that if GPO changed the basis of the formula from an assumed method of sale to the actual method of sale, the effect on pricing could be dramatic [22]. Furthermore, any such pricing changes could be made within the confines of the present law. Assuming that the central premise behind the Sales Program is an intent to give government publications the widest possible dissemination to as many people as can be reached, and at a reasonable cost, then it seemed to the Panel that GPO ought to encourage book dealers to han- dle an increasing portion of the retail business. Indeed, the magnitude of the distribution net- work that could be provided by the retail bookstores becomes apparent when one considers that there are 5,800 branch chain stores, 21,568 retail bookstores, and 14,489 independent book- stores in the United States and 2,080 retail bookstores and 1,321 independent bookstores in Canada. Consequently, the Panel felt it incumbent on GPO, in the face of 44 U.S.C. section 1708's discount limitation, to develop strategies to expand the base of book dealers that handle government publications and that would be instrumental in widening the market for such publi- cations. The solution to that problem lies in a more creative pricing mechanism and in the development of a more flexible application of the pricing formula. Agreeing with past observations of the General Accounting Office (GAO), the Panel realized that whenever books are picked up by the purchaser at GPO's warehouses, there is no postage cost incurred by the Superintendent of Documents. However, because postage is a factor in the pricing formula, the price charged for the publication recovers a cost that is not incurred (231. When GPO ships publications to book dealers in bulk, the actual postage cost is lower than the factor built into the pricing formula; thus, the price charged in that case over-recovers for this cost. Since the key language in 44 U.S.C. section 1708, "cost as determined by the Public Printer," requires, as GAO once s~aid, that the costs reflected in the formula must have a basis in fact [24], insofar as the publication. that are sold to book dealers actually recover costs that are not incurred, the pricing formula as applied to them does not meet that standard. The Panel's proposed solution to this shortcoming is a pricing structure flexible enough to more accurately relate prices to cost. The Panel saw such a flexible pricing structure as essen- tially having five component parts; i.e., price variances for the same book based on the actual method of sale: (a) retail price (developed from the existing formula), (b) bulk retail price (de- veloped from existing formula, less 25 percent discount); (c) book dealer retail price (99 copies or less) (same as bulk retail price); (d) book dealer warehouse price (retail price less 25 percent 44(cid:127), S.M FOSS discount. less 150 percent of postage if the publications are picked up by the book dealer from the Superintendent of Documents' warehouse, or the book dealer uses a commercial carrier, or any other means by which no shipping costs are incurred by GPO). and (e) book dealer bulk shipment price (retail price less 25 percent discount, less 150 percent of postage. plus 150 per- cent of the bulk shipping costs from the warehouse) (25]. By the Panel's calculations, using this more realistic pricing method could result in effective discounts to the book dealers ot nearly 45 percent, which would be in accord with trade practice 1261. The tPanel aiso had to recognize that apart from the need for larger discounts. GPO %,ould have to change its current invoicing practice in older to attract wholesale customers. Book deal- ers prefer to be invoiced or billed for the merchandise they purchase. and that is the commer. cial practice followed in the industry. In contrast, the usual practice at GPO, as it is %ith most governmental entities, is to require payment in advance, i.e., before an order is shipped [27]. However, the Panel believes that a reasonable balance could be struck between the needs of GPO's book dealer customers and the views of its program managers by a policy that allows GPO to invoice "its best non-Government customers." It was unwilling to recommend a "*blanket" or unrestricted invoicing policy for GPO; indeed, the law itself forbids selling some publications on credit [281. Furthermore, the Panel cautioned that a complete and sensible in- voice program should also include a collection method to minimize potential loss due to bad debts [29]. I Finally, the Panel recognized that, as with any new undertaking, there is no way to know at this time if greater efforts to wholesale books will result in more sales of government pub!ica- tions or merely to lost revenue. Consequently, the Panel recommended a one- to two-year pilot or demonstration project in which selected publications, chosen from GPO's consistent best sellers, are offered under the reconfigured pricing system to book dealers and others who pur- chase for the purpose of resale. In order to be effective, a demonstration project of this nature will need to be promoted by GPO through vigorous advertising and marketing campaigns. and would be perhaps most effective if, at the outset, efforts were concentrated on the independent bookstores, and the classified stores of the book chains (stores that cater to specific topics). Moreover. the Panel thought that the project's success would be enhanced if the Public Printer made two alterations to GPO's current bulk order policy: (a) redefine such an order to be a lower figure than 100 copies, and (b) allow book dealers to use a mix of assorted titles to make up the bulk order. MARKETING ISSUES A more direct approach to changing the current 25-percent limit on book dealer discounts in the statute is for GPO to seek new legisla- tion that would allow the Public Printer to establish a discount policy commensurate with the conditions and practice in the industry. The Panel recognized that its modified pricing formula with respect to wholesale distributions constituted an indirect approach to the establishment of an effective book dealer discount that matches or exceeds the industry average (40 percent) and was one way to overcome the obsta- cle to increased sales caused by the 25 percent cap on discounts in 44 U.S.C. section 1708. The Panel also knew that its preferred flexible pricing method was at odds with GPO's tradi- tional position that the agency could not, as a matter of law, offer publications through the Sales Program to book dealers and others at more than a 25 percent discount-higher discounts to them would require a change in the law (301. This direct approach to solving the problem caused by the current 25 percent discount limit, Dissemination of U.S. government information 441 i.e., to ask Congre;s to raise the discount to at least 40 percent, was the avenue chosen by a former Public Printer in 1982 [31]. In the Panel's view, the reasons that prompted an attempt to change the statute are still valid; the discount policy in the law is out of step with industry practice and deprives GPO of access to commercial marketing outlets that are essential to a policy of maximizing the dissemination of government publications [32]. Because of the statu- tory discount cap, certain publications with a potential market well beyond what can possibly be reached through the GPO bookstores and by mail (e.g., Infant Care, The Statistical Abstract of the United States, Occupational Outlook Handbook, The Back-Yard Mechanic, Railroad Maps of North America, ýifr, Birds of Town and City, Restoring America's Wildlife, 1937-1987) are not stocked by com nercial book dealers for sale in their stores. As an alternative to modifying the application of the pricing formula to better reflect the actual costs incurred by book dealers and othei volume purchasers for resale, the Panel be- lieved that the onlyt other solution is to ask Congress, once again, to amend 44 U.S.C. section 1708 to remove the present discount limitation of 25 percent. It did not suggest a fixed higher ceiling, however, thinking it more appropriate and more flexible if the substitute language were to allow the Public Printer to establish a discount policy commensurate with the conditions and practice in the industry. Until the 25 percent discount cap is eliminated, the Panel recognized there is no way to know if a higher discount rate will result in more sales. On the other hand, the Panel was unwilling to recommend an unlimited offer of government titles .to the private sector without first testing their sales elasticity in the absence of the present restriction; indeed, for some pub- lications it may be inappropriate to offer a 40 percent discount, since doing so would reduce the price below cost. Therefore, consistent with its position on the flexible pricing method, the Panel recommended that the Public Printer seek permission from Congress to conduct a one- to two-year experiment or pilot project in which selected publications, chosen from GPO's consis- tent best sellers, are offered to commercial, university, and college bookstores at a discount that meets the standard in the industry. This experiment should also conform to the same crite- ria regarding sales on credit, the treatment of postage, and vigorous promotion that the Panel felt would be needed to make the flexible pricing pilot project a success. In the final analysis, the Panel believed that an experiment of controlled size and duration is a much better way to enter the arena of commercial outlets than an immediate blanket change for all of the titles sold by GPO. GPO's traditional policy of selling excess publications as scrap is not a legal requirement, but is based on a previous management business decision. Therefore, the Public Printer should permit appropriate over- stocks to be sold to book dealers and other quantity purchasers, as surplus property. GPO's practice of pulping overstocked publications has been the subject of a continuing de- bate for more than three decades [33). The principal focus of this controversy concerns the disposal of excess but otherwise usable publications, rather than the destruction of damaged or obsolete stock. Like commercial book dealers, GPO cannot always accurately predict the sales performance of the publications and documents that it sells, and thus the question becomes how to dispose of slow-moving or nonmoving stock. For years, the general perception within GPO has been that overstocked publications must be sold as scrap, as a matter of law. However, the Panel's extensive research on this issue disclosed that, in fact, GPO's practice of pulping over- stocked publications, instead of selling them at reduced prices, was a management decision rather than a legal requirement. In this regard, the Panel could find nothing in 44 1,1 442 S.M. FOSS U.S.C. expressly mandating the sale of surplus property as scrap, nor is there any language explicitly prohibiting an alternative treatment of excess stock [34]. 0 Its review of the issue led the Panel to several conclusions: (a) the law distinguishes between disposing of surplus property by sale and giving it away (as a general rule, with limited excep- tions, donations are not allowed. (b) 44 U.S.C. section 1708 governs prices for publications sold by the Superintendent of Documents (as long as documents are controlled by that office, they can not be considered surplus. and there can be no de,,iation from the pricing formula): (c(cid:127)) the Public Printer's decision that certain publications are overstocked removes them from the control of the Superintendent of Documents. making their disposition a ma:ter of the Public Printer's management discretion under the law [35]: (d) the sales price of excess overstocks is not governed by 44 U.S.C. section 1708, because they are no longer considered viable govern- ment publications, but rather are deemed to be scrap. surplus, or condemned matter, which, in 0 the exercise of good management judgment. may be sold at prices other than those set in accor- dance with the statutory formula; and (e) the policy of selling overstocked publications as scrap material is a long-standing management practice and is not mandated by statute. In the Panel's view. any method of disposal that maximizes revenue may be employed by 4 GPO management, so long as the sales proceeds frorn surplus property and publications are recovered in'o the revolving fund [36]. Further, it seemed clear to the Panel that rather than being a creature of the law, the policy of scrapping overstocked publications was supported by. in the main, business perceptions based on conditions in the industry [37]. Consequently. once responsibility for overstocked publications is removed from the Superintendent of Documents. there is no legal impediment to selling them as surplus for more than their scrap value, i.e., the law only precludes such sales under the auspices of the Superintendent of Docu- ments [38]. The Panel saw multi-year subscriptions as being underutilized as a marketing tool and recommended that the Superintendent of Docu- ments, in cooperation with the agency/publishers, endeavor to con- vert more single-year subscriptions into multi-year subscriptions. 4 Most subscriptions available through GPO's Sales Program are marketed on a one-year basis [39]. In recent years, however. GPO has reexamined its sales policy regarding publications sold by subscription and has changed a number of them to a multi-year format: e.g., The Commerce 4 Business Daily, Monthly Labor Review. Consequently, the Panel considered whether the use of multi-year subscriptions could be extended to more publications. The Panel recognized that the key to the effective use of multi-year subscriptions is a stabili- zation of prices for the publications concerned. Prices are set on an annual basis. Further, when a publication enters the Sales Program, its price is established based on its cost at that time, and that remains the price for the publication's life cycle. Consequently, regardless of any post- age increases, GPO would need an agency/publisher's cooperation in order to change a publica- I tion to a multi-year sales format [40]. That is to say, the agency would have to commit to GPO that no significant changes will be made to the printing specifications of the publication during the multi-year period covered by the subscription. This will have the effect of stabilizing the price of the publication, and will also allow GPO's Marketing Department to make the appropri- ate changes to the order blank used by the customer. Therefore, the Panel recommended that increased ways be found to use this marketing technique. The Panel also believed that consolidated shipments were underuti- lized in the Sales Program and recommended that the Superintendent Dissemination of U.S. government information 443 of Documents take steps to advertise that method of distribution to * increase its use. Consolidated shipments are an agency-initiated method for bulk distributions. It is basically a distribution service provided by the Superintendent of Documents to customer/agencies. Under this method, the ordering agencies themselves are responsible for advertising the publication, usually by means of a flyer, and for getting an order blank to the customer. When functioning properly, consolidated shipments can result in a substantial monetary return to GPO-in the past. this sort of advertising has usually added $100,000 worth of sales to the original publication. The Panel was informed that GPO does not advertise consolidated shipments as a means of distribution. Nonetheless, the Superintendent of Documents certainly has the capability of ful- filling more orders by means of consolidated shipments, if the central administrative problem of dilatory responses to the agency's flyer can be controlled. Therefore, the Panel recom- mended that steps be taken to advertise that method of distribution and find ways to increase its *, use 1411. SALES PUBICATIONS PRICING APPEALS No formal pricing appeals procedure needs to be established at this time because agency/publishers are generally satisfied with the pric- ing structure applied to government publications sold through the Sales Program. One of the motivations for the creation of the Panel was a concern that the pricing mecha- nism established by 44 U.S.C. section 1708 was relatively rigid in application and that circum- stances might occasionally exist when variations to the formula were warranted. Accordingly, the Panel decided to find gut if there was a need for a formal pricing appeals system that could be invoked by agency/publishers if they wished to challenge the price assigned to one of their publications under the pricing formula. The Panel's thinking was that if it found significant or broad dissatisfaction with the pricing mechanism, this would support the creation of a process by which the agency/publishers could make a case for a different, presumably lower, sales price. The Panel's discussion of this issue relied on the results of a telephone survey it conducted of a representative sample of agencies that were known to publish and have various publica- 4 tions included in the Sales Program. In all, 41 agencies (of the 138 customer/agencies served by GPO) were contacted. Of the agencies surveyed, 57 percent were satisfied with the prices at which their publications were sold through the GPO Sales Program, 29 percent were somewhat satisfied, and only 14 percent were dissatisfied. Stated somewhat differently, 86 percent of the federal government publishing community was basically satisfied with the prices assigned by GPO to their publications. On thig evidence, the Panel concluded that such a low rate of dissat- isfaction simply did not provide a sufficient basis for a formal pricing appeals procedure. On the other hand, while the Panel recommended against the creation of a formal pricing appeals process, it observed that an ad hoc working group within the Public Printer's Inter- agency Council on Printing and Publications Services (ICPPS), that was then looking at Sales Program issues could be given permanent status and allowed to serve as an appropriate infor- mal conduit for agency/publishers to express their views regarding the pricing of particular publications. 44-4 S.M. FOSS OTHER ISSUES The Panel recommended that the Superintendent of Documents accel- erate the conversion of the Sales Program to the ISBN and ISSN iden- tification systems. Two identification systems, the International Standard Book Number (ISBN) system and its complementary numbering system for serial publications, the International Standard Serial Num- ber (ISSN), are used by more than 30,000 active publishers in the United States. They are the most widely used identifiers for publishers, jobbers, bookstores, and libraries in the acquisitions process, and are key elements in standard acquisitions tools such as Books in Print. The sys- tems have been embraced by the publishing industry primarily because they facilitate the sale of books and publications. At the present time, the Superintendent of Documents is taking steps to convert the publica- tions identification system currently used by GPO to the ISBN and ISSN systems. The Panel endorsed the Superintendent of Documents efforts and urged an acceleration of the conversion process so that all of GPO's sales publications conform with the industry's identification stan- dards in the near future [42). An ad hoc working group of the ICPPS was a potential advisory body for the Sales Program, and the Panel recommended that it be given permanent status for that purpose. For years, GPO has had advisory councils or committees for the Depository Library Program (the Depository Library Council to the Public Printer) and the Printing and Procurement Pro- gram (the ICPPS). However, GPO does not have an advisory committee specifically for the Sales Program. Some voices now suggest that the time is ripe for a similar external advisory group for the Sales Program [43]. The role envisioned for such an advisory group is to assist GPO in developing more aggressive marketing strategies for the Sales Program as a whole. The Panel was aware that the establishment of advisory committees in the executive branch is strictly controlled by law-the "Federal Advisory Committee Act" [44]. While this statute does not apply to GPO, the Panel was nonetheless mindful of Congress' view that "new advi- sory committees should be established only when they are determined to be essential and their number should be kept to the minimum necessary" [45]. Consequently, the Panel was hesitant to recommend that the Public Printer create a new advisory group for the Sales Program, in the avbence of comapelling reasons indicating the need for one. Instead, the Panel focused on an existing informal working group of the ICPPS, then looking into other Sales Program issues, as potentially fulfilling that role. It recommended that the informal working group be made a permanent subcommittee of the ICPPS with advisory responsibilities for the program. As the Panel saw it, doing so would not only satisfy the perceived need for an advisory group devoted solely to the Sales Program, but such an action would be consistent with the goal of Congress that agencies limit the number of advisory committees and create new ones only if they are essential. Although the Panel set out to consider the pricing of electronic publi- cations, it realized that pricing of these is only one part of a larger issue involving, among other things, the proper placement of the elec-