Oppose the Change to Montana Public Library Standards

The Montana Library Commission is considering drastic and unnecessary changes to state Public Library Standards. EveryLibrary is supporting the Montana Library Association's urgent request that library stakeholders and advocates file "public comment" opposing these changes by December 1, 2023. 

The official notice about the new rule is available from the Montana State Library Commission. The amendment we are most concerned about is:

Amendment to 10.102.1160 Personnel: This amendment to remove the requirement for directors of libraries that serve over 25,000 people have a Master in Library Science or equivalent degree is proposed to reflect the Commission’s opinion that local boards should be given responsibility to set library director qualifications as the size of the community may require a different skillset or knowledge base for the library director.

This proposed change is in response to a problem at one library, Imagine IF, but will directly start to professionalize libraries across the state. A recent editorial in the Daily Montanan says it well, "The recent proposal to eliminate the graduate degree requirement for library directors raises serious concerns about the future of library leadership and the services our community expects. The ImagineIF Board’s pursuit of a lower standard for their library director has now affected the State Library Commission, creating a race to the bottom that does a disservice to all Montanans."

The Montana Library Association needs everyone who is interested in effective, professional public libraries to show up and make comments in opposition to this change. The State Library Commission is receiving public comment through December 1, 2023 at 12n MST. Please visit the "Revised Public Library Administrative Standards Review" page to make your voice heard and share your concerns.  It is easy to do - and it is critically important. 

We are reproducing the MLA Fact Sheet below to help you frame your comments. 

Take a stand for librarians and submit your public comment today. 

MLA Fact Sheet on Amendment to 10.102.1160

Public Comment is currently open on the proposed changes to the Public Library Standards. MLA’s Government Affairs Committee wanted to share some information that may be valuable to you in crafting your public comments.

Public comments can be submitted here. The deadline for making comments is Dec. 1 at noon. The public hearing will be Dec. 1 at 1 p.m., via zoom. 

First, it is important to consider the Commission’s rationale in proposing these changes, which are outlined below. 

• “Local Control” - This change would return authority to local communities,
• 25k population is arbitrary - why should larger communities be treated differently than smaller communities?
• Establishes a more fair process for hiring a director - a Director with work and/or business experience will have an equal opportunity

Each of these arguments were presented by Members of the Commission and of the Task Force, both in public session and in press interviews.  

The GAC has heard from many of you regarding the proposed changes, and have compiled the following list of talking points that you can consider using as part of your own comments.  PLEASE DO NOT COPY/PASTE THESE TALKING POINTS!  Use as many or as few as you like, but please take the time to re-work and personalize them for your own voice:

• Public comment is overwhelmingly in support of keeping the standard.
• The role of the Commission should be to encourage measurable excellence.

• 1. “Local control” is not a measurable standard.  Library Boards, including ImagineIf, have the right to exercise local control by choosing whether or not to meet the standards.
  2. Establishing new standards/certifications is an unnecessary complication.  This action by the MSL Commission is the very definition of wasteful bureaucracy.

• The MLIS requirement is limited to libraries serving a population of 25,000 is not arbitrary.  

• 1. It was initially written to recognize that our smallest libraries may not have the tax base to support the salary necessary to hire a degreed librarian. 
  2. Despite this, 13 Montana libraries have hired degreed librarians as directors serving communities with fewer than 25,000 people.
  3. All other “large” libraries have successfully recruiting degreed staff. Most recently, Missoula’s three finalists all had their MLIS degrees.
  4. Exceptions have always existed for this requirement.  ImagineIF willfully disregarded these exceptions at every opportunity.

• Public Library Standards are tied to public financial investment in public libraries of all sizes - they exist to incentivize local investment in staffing and services so that all Montanans can access quality library services.  

• • Eliminating standards at the request of one library undermines libraries of ALL sizes.

• The Commission appointed a diverse Task Force, including a member of the ImagineIF Board of Trustees, to explore, discuss, and recommend action.  
  • The Commission is acting in defiance of their own Task Force, simply because they take personal issue with its recommendations.
    
    
• This change is a “solution” in search of a problem
  • Changes to Administrative Rules should not be used to excuse the behavior of a single Library or Library Board.
  • This change would reward and incentivize similar behavior across the state,
  • This change eliminates accountability for destructive behavior of Library Boards.

You are, of course, welcome to write public comments however you like, but these points are representative of MLA's position on the proposed changes, and will be used in our own communications to the Commission.  The strongest message is a consistent and disciplined message, so we appreciate your consideration.

Additional MLA Points to Consider for Public Comment. MLA's resolution supporting professional librarians is at https://www.mtlib.org/news/13279010.  

• This change was made because of one bad actor.
• Policymakers should not make policies based on exceptions.
• 13 Montana libraries have hired degreed librarians as directors despite serving fewer than 25,000.  Some of the smallest are Columbus and Ekalaka.
• Two years ago when the updated standards were adopted no one questioned this standard.  We’re wasting taxpayer dollars changing the standard again solely at the request of a minority of people from the Flathead.
• Public comment is overwhelmingly in support of keeping the standard.
• Other libraries are successfully recruiting staff. Most recently, Missoula’s three finalists all had their MLS degrees.
• For the financial investment the state makes in libraries, we should expect to have a way to assess library services fairly.  That is the purpose of the standards.
• Local control is not a standard.  ImagineIf is already exercising its local control in choosing not to meet the standard.
• Undermining this standard is a slippery slope to undermining all standards.
• This standard has been in place for nearly 50 years.
• Instead of putting the state in a position to defend the standard, ImagineIf should have to explain why meeting a standard creates a hardship for their library.  They haven’t because they can’t.
• The only reason this standard is limited to libraries of this size is out of recognition that our smallest libraries may not have the tax base to support the salary necessary to hire a degreed librarian.
• Suggest we create an administrative rule that defines the process for reconsidering the standards outside the normal review process which occurs approximately every 10 years.
• For schools to be accredited, Montana administrative rules require administrators and principals to be licensed.  To be licensed they must have a minimum of a master's degree. See ARM 10.55.702-703 and 10.57.413-415z
  • K-12 schools require librarians/media specialists to be licensed and accredited.

Montana library advocates have a strong and consistent history of standing up for what is right. The recent campaign to preserve the ratio of school librarians to students is one excellent example. EveryLibrary is proud to stand with the Montana Library Association again in opposing changes to the current rule.

Please make your Public Comment before December 1, 2023 at 12 noon MST.