Call for Member Comment: SAA-ACRL/RBMS Guidelines on Access to Research Materials

Thanks for the opportunity to comment, and excellent work getting to this point!

Considerations:

• Second bullet: shouldn't it be "as *are* allowable"?
• Re: “intellectual access” to unprocessed materials, that can be interpreted widely (theoretically, baseline intellectual access could simply mean one maintains offline description about a collection and provides access to that description by request), but it may suggestyou're requiring we tell the public about all unprocessed collections. I am not opposed to this in limited cases, but not all cases, mainly because doing so sends the signal that an unprocessed collection may be accessible. Perhaps this should be *encouraged* but informed by collections management context and capacity to respond in a timely manner to requests for access to unprocessed records. I feel like making this a requirement overlooks to considerable labor implications of timely response to requests such as these. 
• Read through to be sure all bullet points lead with a verb. They all don't.
• Accessibility: we really should be doing more than merely "complying" with the ADA, which is a really low barrier (and is required by law, thus obviating the need to express it here, technically). Really we should be intentionally thinking about how *best* to provide access to people of different physical abilities, not just meet the bare minimum. Disability is often referred to as the "overlooked" diversity, and so this policy would do well to address that.
• You may want to include somewhere that you intend to provide access to users "regardless of identity or ability" to drive home the diversity emphasis.

Thank you for creating these draft guidelines.

I appreciate the succinctness of the guidelines, but I believe there are at least a couple of places where they would benefit from additional detail.

First, I think it would be useful to be more explicit about encouraging repositories to ensure that their security procedures, service points, and spaces are not prohibitively restrictive, difficult to use, or uncomfortable. The Policies section states "Remove as many barriers to access as is allowable under institutional policy," but it doesn't encourage repositories to consider what these barriers to access might be, or how their policies might serve to restrict access. For example, how do repositories allow users to access or edit their account information (e.g. their first name)? Must repositories insist that users provide multiple government-issued ID cards to access material and/or enter our spaces? Who are we excludling, inconveniencing, or harming by following extant security policies, and how are we to weigh those concerns when revising or deciding to continue with our policies? Relatedly, I think that the guidelines should encourage repositories to consider how accessible and welcoming their spaces are to diverse user communities, including non-English-speaking users and trans users (e.g., are there all-gender restrooms?, is there decent way-finding in place to those facilities?, are sanitary products available regardless of bathroom "gender"?). There's a lot to say about how we can make our spaces and collections more accessible and welcoming, I realize, but I hope that at least an clear commitment to providing access to diverse user communities is explicitly reflected in the final document. Essentially, it seems to me that the current guidelines lack the "why" of our commitment to access, and they are sometimes vague on the "how" of ensuring equitable access.

Second, the Formats section states "Accommodate users who request access to digital materials in alternative formats." Should that guideline apply only to digital material, or should it apply to collection material across the board? I realize that providing an alternative format may not always be feasible, but it seems like that would be very useful for access.

Third, the Laws, Regulations, and Restrictions section states "Inform users of restrictions that apply to collections, make this information generally available and apply it consistently." I think this is a bit unclear, but I believe that this bullet intends to suggest that repositories should inform users of collection restrictions, make restriction information publicly available, and apply restrictions consistently from user to user. I think changing "this information" and "it" in the sentence to more specific phrasing would clarify this.

Fourth, the Laws, Regulations, and Restrictions section also states "Discourage donors from imposing unreasonable restrictions, encourage a specific time limitation on restrictions that are imposed, and make the duration of the restriction known to users." I agree with this guideline but think it would be useful to provide additional information on how to determine whether a restriction is "reasonable." 

Finally, the Accessibility for People With Disabilities section states "Comply with state and federal guidelines for accessibility of collections according to the Americans with Disabilities Act (ADA), Web Content Accessibility Guidelines (WCAG), respective SAA and ALA accessibility guidelines, and other related parameters." Perhaps this is referencing specific phrasing elsewhere, but I'm not sure that "accessibility of collections" is all that's at issue here -- should this also include accessibility of our spaces (both our reading rooms, which I think are implied in "collections," and our event/social spaces, which I don't think are implied in the above)?

Thank you again for creating these guidelines and for asking for comments.