United States Government Accountability Office

Washington, DC 20548 

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outdated and nearing the end of its useful life and initiated efforts to plan for a new, 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. 

 GAO-07-871R Talking Books for the Blind 
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 

 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. 

Page 2 GAO-07-871R Talking Books for the Blind 
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;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 

 4 2 U.S.C. §§ 135a–135b and 17 U.S.C. § 121, respectively.

Page 3 GAO-07-871R Talking Books for the Blind 
guidance and government and industry best practices5

 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. 

 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). 

Page 4 GAO-07-871R Talking Books for the Blind 
Figure 2: Victor Reader Classicx Commercial Daisy CD Talking Book Player from HumanWare 

Source: HumanWare Canada, © 2007. 

• 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 

Page 5 GAO-07-871R Talking Books for the Blind 
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: 

• 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. 

 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). 

Page 6 GAO-07-871R Talking Books for the Blind 
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. 

Page 7 GAO-07-871R Talking Books for the Blind 
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, 

Linda D. Koontz 

Director, Information Management Issues 

Page 8 GAO-07-871R Talking Books for the Blind 
Enclosure I: Comments from the Library of Congress 

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