IEEE Learning Technology Standards Committee (IEEE LTSC)
		       February 15, 2005

Background:  In August of 2005 the American Library Association (ALA)
asked IEEE (Institute of Electronic and Electrical Engineers) to
provide a liaison person to their Committee on Cataloguing:
Description and Access (CC:DA), and, in particular, to help
shape a key document, "Resource Description and Access (RDA)."

A copy of the request appears below as Part II.

In response to the ALA request, the LTSC LOM (Learning Objects
Metadata) Committee selected W. Curtiss Priest (MIT/CITS/EPIE)
as the liaison person and Wayne Hodgins (Autodesk Corporation)
as a co-liaison person.  The RDA was discussed at a full day
session in San Antonio, as part of the Midwinter Meeting of
ALA (January 20-25, 2006).  Mr. Hodgins attended and conveyed
our perspective that the current RDA does not sufficiently
deal with cataloging entities that are commonly called "learning

On February 15th, final, formal comments on the RDA were due
and we submitted the following comments (Part I).  The format of
these comments was structured to fit within the web-based submission
tool, Confluence.

Part I:

Note: material between *  * is boldface

*IEEE LTSC LOM-1:* The world of Learning, Education and Training,
which the IEEE Learning Technology Standards Committee represents, is
very much hoping and wanting to gain great benefit from the enormous
experience and expertise of the ALA and library community.  This is
particularly true for the LTSC Learning Object Metadata (LOM) working
group.  2/15/2006

*IEEE LTSC LOM-2:* The need for assistance, with metadata in
particular, arises from the focus LTSC has on developing standards to
enable learning anytime, anywhere which is customized to match the
context of the individual learner.  2/15/2006

*IEEE LTSC LOM-3:* It is not clear that ALA has grasped the totality
and pervasiveness of the "sea change" that is occurring at an
exponential rate in the world of content.  That being a true "paradigm
shift" in the transformation from static to dynamic content that will
be not only dynamic in terms of being assembled in a much more
on-demand fashion, but also content that will be unique assemblies
that are massively customized and ultimately personalized to be "just
right" for the individual "consumer" aka reader, listener, watcher,
learner, teacher, etc.  2/15/2006

*IEEE LTSC LOM-4:* This type of digital, dynamic on demand content is
extremely new and demands holistic rethinking and redefining the
notion of a "resource" and the corresponding changes required for the
metadata to describe such resources.  This new paradigm is dependant
upon massively increased amounts of metadata, classifications and
other domains of which librarians are historically the masters.

*IEEE LTSC LOM-5:* Therefore the current work on the new RDA CC:DA
provides a prime opportunity to both formalize and increase this
relationship and mutual benefits between ALA and IEEE LTSC.  However,
this is only true to the extent which there is a common vision of the
future of learning resources.  RDA works very well for the historic
and often current models of content (and libraries) of "book-like" and
typically "self describing" resources, but much less so with the new
and evolving models of content.  2/15/2006

*IEEE LTSC LOM-6:* Not only is the content itself changing
dramatically, so too are the roles of the producers and consumers of
both content and metadata.   We are seeing the emergence of what
futurists such as Alvin Toffler called "ProSumers" in his 1960's book
"Future Shock".  We will no longer be nicely divided up into being
either a "producer" or a "consumer" (words that are somewhat dated but
still meaningful) and instead we are all becoming both of these.  How
will ALA and others deal with all the content and the metadata which
is being created by "the rest of us"?  Examples of such "mass
contribution" include blogs, wikis, presentation slides, Email,
digital photos, music metadata and more.  2/15/2006

*IEEE LTSC LOM-7:* IEEE LTSC would therefore have the perspective that
ALA is at a critical decision point with this new RDA.  If the focus
of ALA is on revising the historic models of content as typically
large fixed resources such as books, journals, films, etc. and with
similarly fixed metadata records such as the card catalog, then there
is not likely to be much synergy or benefit between ALA and LTSC.  If
however the focus is on addressing these newly emerging models of
extremely modular and dynamic content, then the synergy and benefits
are enormous.  2/15/2006

*IEEE LTSC LOM-8:* Relative to this decision point, it should be noted
that the RDA and CC:DA documents themselves, and the process of
creating and publishing them, reflects the very change in "content" or
resources that is referenced above.  There appears to be considerable
discussion amongst the RDA and CC:DA group members over how their own
documents will be created, published and indexed such as questions
about the decision to have the primary driver and model for these
documents to be "digital" and "web based" format as opposed to "print
based.  We would suggest that this is a very telling example of the
current and rapidly changing models of content and the problems they
present.  ALA would do well to consider this as they decide upon what
direction to take with RDA.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statements-1:* One of the primary
goals of RDA is to be "... a consistent, flexible and extensible
framework ..." yet there is almost complete lack of addressing the
stated goal of flexibility and extensibility of the framework, and
especially by any other than the author and beyond the perspective of
librarians and libraries.  In particular that RDA seems to be based
entirely on the perspective of librarians and libraries, yet the goals
state that this is to be used by all communities.  With literally no
mention of extensibility in the RDA then either the goal statement
needs to be changed or the document needs to address extensibility.

*IEEE LTSC Concerns with RDA Goal statements-2:* Given the other
stated goal of "... description of all types of resources and all
types of content." RDA seems to be based on a very historical model of
resources, essentially books and book-like fixed resources.  Yet the
fundamental change taking place is in the very paradigm or model of
content itself.  The growing majority of resources (content) is NOT
fixed, but rather assembled, increasingly dynamically and more
on-demand, with mass contributions of the content itself and mass
customization of the content upon delivery in a consumable form.

*IEEE LTSC Concerns with RDA Goal statements-3:* There is also concern
with the stated goal to "Be compatible with internationally
established principles, models, and standards.", yet there appears to
be very little reference to or examples of the use of other standards.

*IEEE LTSC Concerns with RDA Goal statements-4:* We would strongly
encourage ALA to follow "standard ways of creating standards" such as
RDA that are flexible and extensible so as to allow for the inevitable
changes and evolution that will certainly continue and accelerate
though the life span of this version of RDA.  With the stated goal of
covering all content and all communities, the importance of following
such "standard approach to developing standards" is even more
critical.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statements-5:* The use of abstract
conceptual models is a particularly good way  to do so.  Along with
the similar suggestions from DCMI, we specifically recommended that
CC:DA create 3 abstract conceptual models for:

*IEEE LTSC Concerns with RDA Goal statements-5-Abstraction 1:*
Resources (content)  2/15/2006

*IEEE LTSC Concerns with RDA Goal statements-5-Abstraction 2:*
Metadata  2/15/2006

*IEEE LTSC Concerns with RDA Goal statements-5-Abstraction 3:*
Services  2/15/2006

*IEEE LTSC Concerns with RDA Goal statements-6:* It may also be of
great interest to ALA that DCMI and IEEE LTSC have recently created a
new joint working group to create a common abstract conceptual model
for metadata.  Participation and tracking by ALA of this new work
would be welcomed and encouraged.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-1A - Further
commentary on how the RDA Achieves Extensibility:*  We note in
"Functional Requirements for Bibliographic Records" (aka FRBR):
"extensibility of expression" (p. 43) defined on p. 44.  Extensibility
reflects the expectation that the expression will have additional
intellectual or artistic content added to it (e.g., an expression that
is completed one part at a time, segment by segment, issue by issue,
etc.).  In the "Functional Requirements for Authority Records" (aka
FRANAR) document, extensible or extensibility does not appear at all.
If we now turn the the Draft RDA, the word extensible or extensability
does not appear at all.  Now, let's also focus on the word "function."
This word is widely used in the background documents, indeed,
appearing in the title of FRBR.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-1B:* In the RDA we
have on page 2, as the "Objectives and Principles" of the RDA:
"Functional objectives and principles of resource description."  But
the use of "function" is to function within the context of locating a
resource (identifying) and providing it to the user.  On page 5 of the
RDA:  "structure and style of the Draft are designed to function in a
web-based environment" but again, function is directed, not at, say
the function of a learning object in relationship to other learning
objects, but, has been subjugated to the function of librarianship.
Indeed, an object, to a librarian is something like a book, or, more
generally an entity.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-2A:*  In that these
issues involving non-standard entities will be extremely alien to many
discussing this RDA, it seems to us that there are two roles we can
play in your revisions:  Above we have discussed the easier problem of
metataging resources.  Our years of taxonomy building and
relationships with others, such as the Dublin Core, is experience to
be drawn on.  We suggest that an RDA revision person join
LTSC-LOM@LISTSERV.IEEE.ORG  This list will be pleased to provide
information in shaping the RDA.  Our second role is to help extend the
envelope.  As Deirdre Kiorgaard, Chair, JSC, in the Strategy document
asked for an "extensible framework" and we do not see that the current
RDA addresses that, we have made various comments on "abstraction" and
extensibility is one key component to abstraction.  Recall that FRBR
document mentions "extensability of expression." And that term, in the
FRBR, is in context of an author.  It says that an author might
"extend" work to include additional work.  From an interest of
knowledge unification, this is not a powerful concept.  We understand
how it comes about.  Libarians deal with entities by various authors.
So, to them, extensability is something the author might do with their
own work.  But, from an object-oriented standpoint this is quite
limiting. An object is extensability because it can inherit new
properties and methods.  And, those new functions are independent of
whoever authored them.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-2B:*  We believe
that the idea of an entity to ALA without authorship (or multiple
authorships via inheritance) is a queer beast.  Indeed, part of your
umbrella of assuring quality has to do with who knowing who authored
the piece.  We believe there is a lifetime of work ahead of us.  For
the ALA community this involves a gradual process in expanding the
role of librarians and libraries in understanding that organizing
resources is not about getting some "gross" entity, like a book, into
a user's hand, but, often rather, information 'when needed, as
needed,' and at a level of granularity that they may not have
conceived of.  And, while web search engines provide a frustrating,
intermediate interface, we do believe that cataloging and access of
ever more granulated pieces raises the need for cataloging that
greatly exceeds what is necessary to access entities of less
granularity.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-3 - Further
commentary on the Abstraction Level:*  We suggest that for the IEEE
efforts (and recent efforts by MIT/CITS/EPIE, below) to be useful to
the ALA efforts, we need to, at least question, where and how an RDA
addresses:  1.)  extensibility; 2.)  function (where an object
performs functions, i.e., have properties and methods);  and objects,
where we wish to assign descriptors and catalog these objects.
Cataloging must go to a level of fine granularity, beyond taging
larger entities created by an author as a whole, and to where objects
become sub-divided from "as a whole" viewpoint.  But sub-divided does
not mean to tag, say, a sentence.  We must make it possible for
authors/creators to find objects, say, on the net, from which these
authors/creators can convey substance to their audience by
inter-connecting existing objects, or creating new objects, and where,
instead of interconnecting words on a page, the author inter-connects
objects such that, via other objects, they can communicate to the
"reader." These objects act in relation to other objects as, say, in
Smalltalk, as described in the MIT/CITS/EPIE AACE paper:  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-4 - Commentary on
the commentary on the Abstraction Level:*  As is discussed in our AACE
paper, hardly anyone agrees what, say, a "learning object" is.
Further, a writer of history on the American Civil War would be
mystified if a librarian gave the historian a GUI (interface) to, not
letters, articles and books, but to some set of "history objects."  No
doubt if handed a piece of lead found at Gettysburg, the historian
would know this physical object, but, this is not an object with
abstraction.  It is, as we define it, an "elemental object."  The
bullet is incapable of describing itself.  But, a bullet abstraction
object could not only describe itself, but, it could relate itself to
the bore of a rifle, could show its trajectory from the rifle, and
could tell how many casualties bullets of its make and era caused.
Such a bullet object could message a bullet casualty object, and that
object could relate any number of known stories about the hardship
caused by such a bullet, including, say, diary entries by a soldier.
A child, instead of writing a "term paper," could work with knowledge
objects, and by "asking them" to "play their parts" in telling a
story, the child becomes, not only the orchestrator of these objects,
but, has, via "inheritance," added to the supply of such objects.
I.e., the emotions, the events, the details that the child has
interwoven is not only presented to his/her teacher, but becomes yet
another object, and possibly one worthy of CCDA taging.  2/15/2006

*IEEE LTSC Concerns with RDA Goal statement, Note-4 - We ask for the
formation of a CCDA Committee to Investigate and help Coordinate
Worldwide efforts to Produce a Learning/Knowledge Objects that possess
the properites of extensibility, and all other properties of a "well
behaved" object as described in the 2004 review "A Condensation and
Review of Various 'Learning Object' Activities and Efforts."

*IEEE LTSC Contact Information-1:* W. Curtiss Priest BMSLIB@MIT.EDU,
IEEE Liaison to ALA  2/15/2006

*IEEE LTSC Contact Information-2 on the IEEE LTSC/MIT/CITS/EPIE
Project on Object Abstraction:* , , ,  2/15/2006

*IEEE LTSC Contact Information-3:* Wayne Hodgins, IEEE Chair, LOM, Co-Liaison to ALA

*IEEE LTSC Contact Information-4:* Erik Duval, Technical Editor,  2/15/2006

*IEEE LTSC Contact Information-5:* IEEE Learning Technology Standards
Committee (LTSC)          2/15/2006 Learning Objects Metadata (LOM)  P1484.12  2/15/2006

*IEEE LTSC Contact Information-6:* IEEE Standard for Learning Object
Metadata, IEEE-SA Standard 1484.12.1-2002  2/15/2006

*IEEE LTSC Contact Information-7:* IEEE Standard for Learning
Technology - Extensible Markup  Language (XML) Schema Definition
Language Binding for Learning Object Metadata, IEEE-SA Standard
1484.12.3- 2005  2/15/2006

*IEEE LTSC Contact Information-8:* IEEE Standards Department,
Institute of Electrical and Electronics Engineers, Inc.  2/15/2006

Part II:

The IEEE Learning Technology Standards Committee (LTSC) is invited to
provide a representative to the Committee on Cataloging: Description
and Access (CC:DA), which is a committee of the Cataloging and
Classification Section (CCS) within the Association for Library
Collections and Technical Services (ALCTS), a division of the American
Library Association (ALA). CC:DA is the primary group within the
United States that provides input and direction to the formation of
descriptive cataloging rules. While these rules have traditionally
been seen as useful mainly to the library community, they have the
potential for being useful to a wider range of communities. For this
reason, CC:DA is formally seeking input from other organizations that
have a strong interest in developing standards for resource
description and access. The IEEE Learning Technology Standards
Committee (LTSC), with its interest in standards for resource
description, is in a position to provide unique and valuable input.

CC:DA has been the primary means for catalogers within the United
States to provide input into the development and revision of the
Anglo-American Cataloging Rules, 2nd edition (AACR2). The committee
serves as an advisory group to the Joint Steering Committee for the
Revision of AACR (JSC). More information about the JSC is available
at: The JSC is now working on a
new code, Resource Description and Access (RDA), for projected
publication in 2008. RDA will replace AACR2. As the new title
suggests, one goal of this effort is to produce a new content standard
that may be usable beyond the library community. Your representative
to CC:DA provides input into the development of this new code. Your
representative will take part in online discussions between meetings
and be asked to attend and participate in person at meetings at ALA
Annual Conferences (usually held in late June) and ALA Midwinter
Meetings, beginning with the ALA Midwinter meeting in San Antonio,
January 20-24, 2005.

The current committee charge for CC:DA is included with this letter,
along with the policy on eligibility of CC:DA representatives. More
information about CC:DA is available at: