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Observations/Relevant Findings

Final Report to Congress on the Joint Resolution to Establish a National Policy on Permanent Papers

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Cost issues

For the 10-month period October 1994 to July 1995, the monthly producer price indices issued by the Bureau of Labor Statistics (BLS) recorded a rapid rise in the cost of all printing and fine writing paper grades. In the aggregate, costs of these paper grades increased an average of 27 percent (from a 17 percent increase for vellum-finish cover paper to a 35 percent increase for offset book paper). These price increases, coupled with the elimination of discounts from retail suppliers, created actual price increases of up to 80 percent for many Government printers. These have been reflected in bids received by the GPO in response to its solicitations for printing and binding. Financial forecasts predict that paper prices will continue their upward spiral for the immediate future.

Both prior to and since enactment of Pub. L. 101-423 in October 1990, a challenge to its full implementation has been encountered because of the high cost of paper that meets the specifications of JCP A270 (uncoated permanent book) -- the only permanent paper available through GPO prior to Government Paper Specification Standards (No. 10). Federal consumers argued that it could not be used as the prime paper for documents of enduring value because its high cost made it economically unfeasible, particularly if multiple copies were required. During consideration of the legislation, the cost of JCP A270 was estimated to be 30 percent above that of offset book paper (JCP A60), the predominant paper used in Government printing, regardless of whether JCP A60 was manufactured by an acidic or an alkaline process. In fact, investigation of GPO paper catalog prices of the time reveals that, for the quarter February through April 1989, A270 was 187 percent more expensive than A60. Also, in 1989, 100% Antique book was used as A270 is today and was furnished to the Supreme Court only. Despite the general rise in paper prices during 1994 and 1995, the price differential between A270 and A60 had narrowed somewhat. The prices that GPO charged agencies during the first three quarters of 1995 are shown in Table 5.

Many factors have contributed to the rapid rise in paper prices since October 1994. The primary cause of uneven price escalation across the entire spectrum of paper grades is attributable to the marketplace dynamic of supply and demand. The fluctuation in price differential evidenced above suggests that the use of A270 for documents of enduring value in other than small quantities would still be prohibitive. However, the same cannot be suggested for the other JCP permanent papers since no historical data are available. Experience suggests that a large increase in demand for A270 and other permanent papers would ensure that the price differential would widen. Initially this might be the case because the papermaking industry would be building its manufacturing capacity to satisfy the demand, and thereafter because total manufacturing capability of the industry is at near capacity. Based on these economic factors, the monitoring agencies reaffirm their recommendation that, as stated in NARA Bulletin 95- 7:

Federal agencies are advised to procure either permanent or alkaline paper grades when creating all Federal records. Permanent paper is recommended for routine use in offices that create and file a high proportion of long-term and permanent records, whereas alkaline paper is recommended for routine use throughout agencies for all other documents.

This is in keeping with the intent of Executive Order 12873 ("Federal Acquisition, Recycling, and Waste Prevention," October 20, 1993) and Environmental Protection Agency (EPA) guidance. The bulletin also states that any paper is suitable for mass production as long as a record copy is produced on permanent or alkaline paper, microform, or electronic medium.

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