COMPLETE OFFICE REORGANIZATION

The second major item was the complete reorganization of the Copyright Office from head to toe. Again, I could go into a good deal of documentation here. I do have a couple of charts, if I can find them, which I might provide for the record, which I think show graphically what the changes were.

[The information referred to follows:]

TOP TO BOTTOM REORGANIZATION

Ms. RINGER. We restructured the top of the office in a way that I think is much more logical and does delegate more authority to the two Assistant Registers whom we have set up in this last year under the Register.

We completely restructured the Examining Division and the Cataloging Division, our two big workflow divisions, to reflect the new classification system and the new workflow. We changed the workflow entirely. Again, as in the revision effort itself, our emphasis has been entirely on team effort. We have gone over to a different bureaucratic approach. The old hierarchical structure has given way in our office to a team approach, and I think our experiments in this area have been very successful.

We split our Service Division into two new divisions, reflecting among many other things the increased importance of making the copyright deposit system work more effectively for the Library of Congress. We have a new law that has a lot of teeth in it, and we are determined to make it work effectively as an acquisitions resource for the Library of Congress.

The new law puts a great deal of emphasis on the records of the Copyright Office as permanent public records and one of our new divisions that comes out of the Service Division will be the Records Division. We have set up an entirely new division to handle a completely new function or group of functions under the copyright law.

COMPULSORY LICENSING

We are required under the new law to run two rather major compulsory licensing systems, on jukeboxes and cable television. We have set up a division, about 15 people, to handle this. It involves licensing of these operations, licensing of each individual jukebox in the country, licensing of each cable operator in the country, at stated intervals, and the collection and accounting for licensing fees.

This is, I think, quite a staggering statistic: since the law was passed in October of 1976 we established 60 new positions and we redescribed 53 more-113 separate classification actions in that one rather short period. I don't know of anything to compare that with.

I should say, Mr. Chairman, that we have had remarkably wonderful cooperation from the unions in this. The two employee unions in the Copyright Office couldn't have been more cooperative. I think our experience was a model of how these things ought to work, and I am most grateful to the staff and to the union for their cooperative attitude. Everybody rallied around. It was a very good experience from that point of view.

LEGAL IMPLEMENTATION

The third big item was legal implementation, some people thought that really all we needed to do under the law was to get out a few new regulations. Actually, we were called upon under the new law to pick up where Congress left off. When the statute got to a certain point and didn't want to go any further into detail, it was

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left to us to get out regulations. Some, not all, of them had to be issued before the new law came into effect. We made it. We didn't exactly beat the deadline by very much in some cases, but we did meet our obligations.

There were 17 separate rule-making proceedings during the year. A few were rather cut and dried, but very few. Most of the proceedings were hotly contested, highly controversial, unfinished business involving details of money in many cases. We had five separate hearings, 55 witnesses, and this resulted in 11 final new regulations, four interim regulations, and four more that are proposals that we will make final within the next month or so.

In the course of that we received 453 comment letters, replies, rejoinders, and so forth, many in the form of full briefs. Somehow we managed to come out of all this alive, though not necessarily unscarred.

In addition-and it furnished backup for all of this-our legal staff completed 61 full-scale legal studies solely on questions arising from the revision. A policy group consisting of five of the top lawyers in the office met and provided answers to literally hundreds of individual questions of legal interpretation.

This was all fed to the policy group through the coordinating committee. It flowed up for decision, and then it flowed back down again to be put into practice.

So much for the legal implementation. I am just scratching the surface, Mr. Chairman.

WORKFLOW CHANGED

Paperwork and procedures was the most time consuming and demanding of all the things we had to do. We completely changed our workflow, and it is a massive workflow. We handle an awful lot of paper. Everything was changed; everything is now done at a different stage and in some cases is done at one end rather than the other. We adopted a completely new classification scheme. We changed all of our application forms and certificates. I can't really over-emphasize, to somebody who has never drafted an application form, how difficult that is; that is undoubtedly the most subtle type of writing and drafting that I know of. It took us, I would say, roughly three solid months to get those application forms in hand, and this was very controversial within the office. We started working on the applications and certificates in January, and began to produce drafts toward the end of the spring, but it took us to September to come up with a final draft of the various application forms that everybody could agree on. We also-and this is ongoing-are in the process of revising or writing new information circulars, revising all of our internal forms, our form letters, our guide letters, and so forth.

Coming back to the application forms for a moment, we had them ready in November and we could have mailed them out. We waited until December because we didn't want to be getting them back in prematurely, since they weren't acceptable until after January 1. This may have been a mistake because we got stacked up with supply requests. I am coming to our big problem in December in a minute. Maybe if I had to do it over again, I would take the chance and go and send them out.