Leadership at the American Library Association and Accessibility: a Critical View
University of Wisconsin-Stevens Point
Reprinted with minor modifications from: Library Hi Tech. 25 (4) 2007: 528-537. Copyright © Emerald Group Publishing Limited.
Purpose – The purpose of this paper is to take a critical view at the leadership of the American Library Association (ALA) and to discuss the extent to which its policies and mode of operation promote, or fail to promote, a barrier-free online library environment.
Design/methodology/approach – Analyses selected ALA policies, and examines the degree to which accessibility advocating groups within ALA participate in the process of policy making.
Findings – Several ALA policies and guidelines dealing with digital resources neglect to address the needs of users with disabilities. The organizations within ALA that are advocates for people with disabilities, particularly the Libraries Serving Special Populations Section (LSSPS) and the Accessibility Assembly, fail to pay attention to policy development in other ALA branches.
Practical implications – Suitable ALA organizations should establish a clearinghouse providing easy access to vendor-supplied information as well as pointers to data collected by independent researchers. Advocates for people with disabilities within ALA need to band together and put in place an organizational structure (a kind of watchdog group) that enables them to systematically monitor, and, if deemed necessary, to respond to the policies and guidelines drafted by other ALA groups. ASCLA, LSSPS, the Accessibility Assembly, and other "disability advocates" within ALA need to lobby the ALA Accreditation Committee to pay attention to the accessibility of library/information science programs and to require a curriculum that ensures that all newly trained librarians understand the needs of diverse populations, including those of people with disabilities.
Originality/value – This is the only article that takes a critical view at ALA's leadership with regard to online accessibility and discusses the extent to which ALA's policies and mode of operation promote, or fail to promote, a barrier-free online library environment.
Article Type: Policy analysis; Viewpoint
Keyword(s): Collections management; Leadership; Policy; Libraries; United States of America.
The American Library Association (ALA) is the largest and most influential professional library organization in North America. In a variety of ways, including legislative lobbying, the issuing of model policy, standards, and guidelines, educational campaigns, the granting of scholarships, etc., it seeks to keep the profession on track in an ever changing social, political, and technological environment. While some might argue, particularly with regard to policies and guidelines, that ALA's activities are fairly irrelevant in the big scheme of things – who, other than some core members, pays attention to them anyway? – I am prepared to argue that ALA's impact should not be underestimated. Whether with regard to information literacy, distance learning, reference services or any other aspect of librarianship, guidelines developed by ALA often serve individual libraries as a starting point for drafting their own institutional policies.
On January 2007, at the ALA midwinter meeting, I gave a speech at the Accessibility Assembly, a standing committee within the Association of Specialized and Cooperative Library Agencies (ASCLA). The Accessibility Assembly is dedicated to the advancement of “ALA's continuing commitment to diversity and to accessibility of library and information services for all, including people with physical, sensory or mental disabilities” . In this speech, I took a critical view at ALA's leadership, questioning whether enough is being done to promote a barrier-free online library environment. Not meant to disregard the many positive things that key groups within the ALA – particularly the Accessibility Assembly and ASCLA's Libraries Serving Special Populations Section (LSSPS) – do in support of people with disabilities, it addressed some serious shortcomings along with suggestions to overcome them.
Here is the text of the speech in its original form (except for some minor editorial changes).
Shortcomings of ALA's leadership with regard to promoting a barrier-free online library/information environment … and what we can possibly do about it
I take it as a given that you understand the basic issue: Accessibility to online resources requires barrier-free design. In principle, the situation is the same as in the physical environment. Web pages that do not provide “electronic curb cuts,” such as text alternatives for non-textual components, proper skip navigation links, meaningful link text etc., pose barriers. Documents in PDF image-only format cannot be read by screen readers. A catalog in which search boxes and buttons are not properly labeled leaves some people stranded. Online surveys, meant to find out about users' needs and wants, systematically exclude the voices of people with certain disabilities if they are not free of barriers. I further assume that you all understand that accessible design serves more than just a “special population.” Especially in the age of hand-held do-it-all devices, it is widely acknowledged that accessible design tends to be good design and that it is beneficial to all. To provide you with an example of how accessibility to online information plays out in real life, let me share with you the following letter, which I received last September from a blind person, a retired psychology professor in Eau Claire, Wisconsin.
Since you're familiar with accessibility issues, I thought I'd seek your advice. I'm blind and use a WindowEyes screen reader. My public library provides a literary database called Novelist, which I would like to use to find authors similar to the ones I like. When I try to access Novelist, I get a “please wait while application loads” message, but it never loads. Apparently, it does load for other remote users, so I'm assuming something in the application doesn't work with screen readers. I was also told that even if I could get into the database, the tabs on the search screen are graphical and don't have alt text tags, so I couldn't use it anyway.
The local library says that it must be a screen reader problem since it works for them. So they referred me to the IFLS assistive tech guy (IFLS is a group of local libraries in this area), and he referred me right back to the local library since they are the ones that contracted with the Novelist database. Bottom line, it's my problem, I guess, but shouldn't the Library have some responsibility for picking databases that work with screen readers or for urging companies to make them more screen reader friendly? Any advice as how to pursue this to a more satisfactory conclusion would be much appreciated.
I had an exchange of some 30 e-mails with Kathie, in which we discussed anything from alternative databases that would suit her needs to legal strategies directed against the Library for its neglect to incorporate accessibility into their collection policy (which, as it turned out, was rather outdated: written in 1976; last reviewed in 1991). Fortunately, of the three other databases considered – LitFinder, What Do I Read Next, and Readers Advisory Online – What Do I Read Next (a Gale product), turned out to be both accessible and cheaper. With at least three-million blind or visually impaired people in the USA, and many more among those who – because of a learning or physical disability – use assistive technology to interact with the computer, difficulties similar to those encountered by Kathie must happen many times all over the country. Most patrons will probably throw in the towel early on in the game. Few people have the energy and courage to speak up. People like Kathie, or the people who initiated the suit against Target Corporation for not making its online shopping site accessible, are likely to be the exceptions.
The point to be made here is that no one, people with disabilities included, should find himself or herself in a position where they have to fight battles. If libraries, proactively, think about accessibility as they build their online environment, many problems of the kind that Kathie encountered could be avoided. Unfortunately, the vast majority of libraries fail in this respect. While many libraries nowadays seek to make their web pages accessible, they utterly fail with regard to the electronic resources they select. Very few libraries have adopted policies that address the issue of accessibility in connection with the selection and procurement of online information products – policies crucial for the building of an overall barrier-free information infrastructure. An extensive web search in June 2006, along with an inquiry posted to pertinent electronic discussion forums, led me to only eight libraries which have such policies, one of which is the library at the University of Wisconsin-Stevens Point, at which I work .
When the vast majority of libraries in this nation fail to see, understand and act upon the problem outlined above, there is reason to suspect that the professional leadership is not doing its job.
Who are the organizations that we should expect to provide such leadership? Two types of organizations come to mind: the schools that train our new generation of librarians and professional library associations at national and state levels, ALA in particular. Let me begin with the former, the nation's schools of library and information science. (I will use the old-fashioned term “library schools” for short.)
Section 54.3.2 of the ALA Policy Manual – a section containing the Library Services for People with Disabilities policy written by this honorable body (the Accessibility Assembly) in 2000/01 – recognizes the severe underrepresentation of people with disabilities both among library users and within the library profession. As a remedy, it suggests certain measures to recruit people into the library schools and it strongly recommends that all graduate programs in library and information science “should require students to learn about accessibility issues, assistive technology, the needs of people with disabilities … ” etc. .
Well documented data that I have collected – in the past by myself, and more recently collaboratively with Dave Comeaux – show that our schools of library and information science are not at all shining examples when it comes to the implementation of this policy – if one takes the accessibility of their own web sites as a measure: While there has been some progress over the past four years, most SLIS web sites are full of barriers (Comeaux and Schmetzke, 2007). Data collected in Nov. 2006 reveal that, on the average, only 47 percent of the top level web pages are free of accessibility barriers (with 41 percent, this percentage is even lower for the homepages), and that, on the average, there are 4.5 barriers per page. Accessibility data for individual library schools, and for the libraries on the same campuses, vary widely (see Table II in the article). Keep in mind that these figures only reflect conformance to basic accessibility design principles, to the extent that Bobby, a software-based accessibility evaluation tool, can measure them, and that we are not talking about the actual usability of these pages, which would put the bar for good design a few notches higher.
The results are not particularly surprising. A 2000 survey comprising the nation's ALA-accredited library schools found that in only 38 percent of the responding schools are adaptive technologies, as they are used by some people with disabilities, covered in the required part of the curriculum (Walling, 2004).
Wouldn't it be nice if the organization that accredits our nation's library schools would ensure that the programs that train the next generation of librarians are fully inclusive (and would thus help increase diversity among librarians) and that the curricula of these programs were such that each and every graduate enters the profession with a solid understanding of accessibility issues? Perhaps, if that were the case, graduates would be more likely to do, proactively, the kind of things that would prevent people from being placed in the frustrating position in which Kathie had found herself, when she tried to access the Novelist literary database.
As you know, the organization responsible for quality education at the nation's library schools is the “Accreditation Committee,” one of ALA's standing committees. To outside observers, such as myself, it appears that ALA's top-level policy, as expressed in its Policy Manual, has not found its way to the Accreditation Committee.
Now that my attention has shifted to ALA, let me point out some other areas where, in my view, ALA's leadership role is weak with regard to online accessibility issues. I shall limit myself to the following three areas: distance education, collection development, and digitization. In addition, I shall also comment on ALA's own web site. ALA's position in the area of distance education is probably best reflected in its “Guidelines for Distance Learning Library Services” – a document that, undoubtedly, has been influential in shaping the policies and practices adopted by academic libraries across the nation .
Even in its most recent (2004) version, nowhere in its ten sections is accessibility for students with disabilities addressed. While the philosophy section underscores that “access to adequate library services and resources is essential,” and while the services section requires that library services “should be designed to meet effectively a wide range of informational, bibliographic, and user needs,” disability-related access needs are not mentioned.
Fortunately, something good is currently happening with regard to the ACRL Distance Learning Guidelines; they are being revised. The present draft of the revision contains at least some of the accessibility-related language that I had proposed to the Distance Learning Section (DLS) Guidelines Committee. However, this good news comes with a shadow: the process seems to take forever. I had first broached the issue, publicly, in a paper entitled “Distance education, web-resources and compliance with the Americans with Disabilities Act,” which I presented at the 2001 ACRL Conference in Denver and which was published in the conference proceedings . My e-mail from 2001-2002 shows discussions with Audrey Gorman, then Director of the Roads to Learning initiative, about the changes to be made, which where passed on to the distance learning folks. Several presentations and numerous personal e-mail exchanges later, I realized, in late 2003, that nothing had moved. I then decided to bring the issue to the attention of ASCLA-LSSPS, where it was discussed at the 2004 ALA midwinter meeting. Subsequently, ASCLA-LSSPS contacted the DLS, and, one and a half years later (2005 ALA conference), its Guidelines Committee held an open hearing, followed six months later by a working session (2006 ALA midwinter meeting). The drafted revision has been sitting on a wiki for a year now, and it is my understanding that further review is to take place. As the chair of the Guidelines Committee informed me, with some luck, the approval process may come to its glorious completion in 2008 – that is, seven years after the issue was first brought up.
Collection development is the second area in which ALA's leadership with regard to online accessibility falls short. ALA's Collection Management and Development Section of the Association for Library Collections & Technical Services is the logical place to look for general guidelines in this area. Not finding such – neither for print nor for electronic resources – I looked elsewhere. What I did end up finding is the 2004 Selection Policy promoted by Choice magazine . Since Choice is published by ACRL, one can safely assume that it reflects ACRL's own position.
Unfortunately, accessibility is not on the radar screen of this policy either. In its section on “Criteria Specific to Electronic Resources,” the “Hardware and Software” criterion comes closest to addressing accessibility, but it clearly falls short of actually doing so: “Technical requirements of a product should be compatible with standard and commonly available hardware/software in libraries.” Not many librarians will take this as an encouragement to select electronic resources that are compatible with commonly used assistive technology, such as the screen reader that Kathie in Eau Claire is using. And if anyone in this audience can name me one vendor, who, upon reading this criterion, will say to himself or herself “Hmm, I'd better ensure that my products are designed with accessibility in mind – for then they will sell better,” I'll buy you dinner tonight.
I also looked at the specific Library Collection Policies which the RUSA/CODES Collection Development Policy Committee had compiled and posted, presumably as good models, on their 2003 web site. Sampling every other policy, and then searching it for pertinent keyword stems (accessib*, barrier*, and disab*), I did not find a single policy that addresses accessibility issues.
Failing to promote accessibility as one of the selection criteria for electronic information sources, ALA also does little, if anything, that would help libraries to implement an inclusive collection policy. To be specific, ALA does not send a strong and clear signal to database vendors that accessibility is important, nor does it offer information that would help librarians decide whether a particular online resource is accessible or not.
A third area that has been neglected, until recently, by ALA is that of digitization. Recognizing that increasing amounts of money are spent on digitizing information sources without a “coherent body of policy to guide decision-making,” ALA's Office for Information Technology Policy (OITP) initiated a Task Force on Digitization Policy . Of the three documents issued in connection with this effort, including the current draft policy “Principles for Digitized Content” , none addresses the need to consider accessibility when planning and implementing digitization projects. This is surprising insofar as the OITP itself has a tutorial called “Accessibility Basics for Librarians,” which provides excellent guidance to those who strive to make the library environment, including its electronic resources, accessible to all .
A critical view at ALA's leadership with regard to online accessibility must include ALA's own internal use of online resources for disseminating information and communication among its members. Let me thus make a few comments on the accessibility of ALA's web site and the process by which input about its design is being solicited.
The ALA Policy Manual requires that ALA's own web site “must conform to the currently accepted guidelines for accessibility, such as those issued by the World Wide Web Consortium.” Hearing complaints about this not being the case, I volunteered to take a cursory look at the ALA web site. So did Simon Healey, who, as a much experienced screen-reader user, is in a much better position to make an assessment under real-life conditions . Despite some differences in our evaluation methods, we more or less arrived at the same conclusion:
On first impression, upon visiting the ALA homepages and several subsidiary pages, we both were surprised at the lack of critical issues. These pages seemed to be quite accessible; our worst fear certainly had not come true.
However, on closer examination of a larger set of pages, problematic issues surfaced that, if added up, detracted considerably from the initial favorable impression. Barriers found included lack of alternative tags for images and image-map hotspots, failure to explicitly associate form controls and their labels with the “Label” element, and ineffective use of skip-navigation links. In many instances where text was provided for images, headers and pop-up boxes, the text did not make sense. As Simon noted, these issues were particularly prevalent among the pages that had been recently updated, including those related to job searches and the Midwinter meeting and the Annual Conference. Simon proposed the following explanation: “It seemed to me that the original designers of the ALA web site had studied, understood and implemented basic accessible design standards issued by the federal Access Board under Section 508. It seems that thus understanding of basic accessible design standards has slipped in the creation of ‘newer’ pages.”
Of particular concern is the inadequacy of the recent ALA web site usability survey – on two counts. First, the survey did not include a single question explicitly addressing accessibility issues. Second, it added insult to injury by using an online survey tool (Survey Monkey) that itself was inaccessible. Obviously, there is a sad disconnect between the ALA policy, which requires conformance with acknowledged accessibility standards, and the recent folks in charge of the ALA web site revision.
Let me recapitulate: Looking at several examples, I have pointed to discrepancies between ALA's top policy, as expressed in its Policy Manual, and the reality prevailing at the institutions at which these policies are targeted: library schools, libraries, and the inner workings of ALA itself. What is it that causes these discrepancies? And what can be done about them?
While I do not pretend to have pat answers to these two questions, I do have some hunches:
First of all, ALA is a huge creature with many heads. With so many activities going on at the same time (especially during its annual conferences and meetings), members in one section are prone to miss, or to forget, what is happening elsewhere. It is close to impossible for one individual to keep track of it all. Perhaps, policy additions, such as the section pertaining to Library Services for People with Disabilities, are taken notice of at the time of initial review, but once they are accepted they tend be forgotten.
Second, there are certain weaknesses within the Library Services for People with Disabilities policy itself. I shall mention two of these here:
(a) It strikes me as odd that the section containing the Library Services for People with Disabilities policy is listed in the ALA Policy Manual under the broader heading of “Equal Employment Opportunity.” This is not to say that it has not an important role to play here, but those seeking to make resources more accessible to library users are unlikely to look for it in its present location. But, perhaps, this is a minor point.
(b) What really bugs me is that the policy does not always convey in a straight-forward manner what librarians, both those in the trenches and those in other ALA divisions who are drafting policies pertaining to electronic resources, need to hear loudly and clearly. What librarians in the trenches need to hear is that for any online resource, from home-stricken webpage to vendor-provided database, the issue of accessibility needs to be raised – with one's peers and, if applicable, with the respective vendors. Our colleagues in other ALA divisions who are involved in the drafting of policies pertaining to electronic resources need to hear that they can't get by without explicitly addressing accessibility.
The Library Services for People with Disabilities policy does not convey this information: while it does recommend, in general terms, “us[ing] strategies based upon the principles of universal design to ensure that library policy, resources and services meet the needs of all people,” it fails to explain adequately what that means for particular areas. For example, under the “Collections” subheading, it states that “library materials must be accessible to all patrons including people with disabilities. Materials must be available to individuals with disabilities in a variety of formats and with accommodations … ” Sure, talk about “a variety of formats” and “accommodations” makes sense with respect to print-based resources. With regard to electronic resources, it is actually rather counterproductive; for the beauty of an accessible online resource is that it is designed so that it meets the needs of all sorts of people, no matter how they interface with their computer. Properly designed, there should be no need for alternative versions. What can we do about these shortcomings? In general terms, what is badly needed, in my view, is a body that acts as a herd of watchdogs with very loud barks. When one watch dog barks, the whole herd perks up their ears, assesses the situation, and if good cause is found, identifies the key players and strategizes on how to best approach them. The general idea is to be proactive, not reactive; to monitor actively and systematically, not to passively wait until, by sheer coincidence, someone stumbles upon a problem. Essentially, the watchdog body that I propose needs to do the following:
(1) With regard to existing ALA policies and procedures, it must identify the ones that deal with online resources, take a close look at these, and, where an explicit accessibility mandate is not included, initiate the respective revision process.
(2) With regard to all major ongoing activities, initiatives and policy developments within ALA, the “watchdog body” must closely monitor what is going on and become vocal whenever it senses that accessibility issues are not, or not sufficiently, considered.
Had such a group been in existence, the current Website redesign fiasco, with no accessibility question asked in the survey and with the survey tool itself being inaccessible, could have been aborted before it had a chance to unfold.
In the same vein, such group could have become aware of the activity of the Task Force on Digitization Policy early on, thus increasing the chance of having its voice heard and incorporated into the policy document.
In both cases, it seems prudent to look for strategic allies within the ALA sections in which policy or procedural changes are sought.
Earlier, I already hinted at another initiative that ALA should get involved in: facilitating access to information about the accessibility of online products, such as databases. I envision a well maintained clearinghouse that would contain vendor-supplied information as well as pointers to data collected by independent researchers. Back in 2003, I made a feeble effort to get something of this sort started . However, the job turned out to be too big for me. It would be better done by a team of dedicated individuals working under the auspices of ALA. At some point, I toyed with the idea of an adoption type of scheme (as in Adopt-a-Highway), whereby individuals would commit themselves to monitoring and reporting on selected resources.
I should point out that the idea of a clearinghouse is already being implemented by the Federal government. Vendors are encouraged to fill out a “Voluntary Product Accessibility Template (VPAT),” which government procurement officials can then access via a searchable database called the “Buy Accessible Wizard” [12, 13].
I know too little about the composition and workings of ASCLA in general, and LSSPS and the Accessibility Assembly specifically. Whether any of these organizations could assume the proposed watchdog and clearinghouse roles effectively, or whether any of these could call into being a special task force or initiative with the mission to do so, goes beyond my current understanding on how these organizations function. If you find sufficient merit in the points that I have just made, it will be your task to figure out how to get the proposed watchdog body and clearinghouse going.
Afterword (December 2007)
My speech, delivered to the ASCLA Accessibility Assembly during the 2007 ALA-Midwinter conference in Seattle, was well received. The Assembly called into being an ad hoc committee to look into the issues raised and the recommendations made (Accessibility Assembly Meeting Minutes, 1/20/2007). My inquiries about the progress of this group in May 2007 revealed that it had not even begun to pursue its mission. The responses to an inquiry addressed to members of the Accessibility Assembly after its meeting in June 2007 are even more dire. If I interpret the Chair's e-mail communication (July 2) correctly, the ad hoc committee was abandoned before it had even started – in order to avoid duplication with the work of two different ASCLA committees. (As of Dec. 28, 2007, minutes of this meeting were not yet available.)
Under the new leadership of Barbara Mates, ASCLA is planning two ad hoc committees – one to develop a checklist which collection development librarians could use to determine whether databases are accessible, and the other to establish guidelines for academic and public libraries stipulating a certain minimum of furnishings, collections, and technology. Only the first one relates to one of the core concerns that I had addressed in my speech: the difficulties that librarians face when trying to make informed decisions when selecting databases. Whether my suggestion, the establishment of an ALA-sponsored clearinghouse providing information about the accessibility and usability of commercial databases and other online library resources, will be considered, along with Barbara Mates' proposal to develop an accessibility checklist, by the respective ad hoc committee remains to be seen. It seems likely that none of these two committees will address my second major suggestion: to put in place an organizational structure that enables advocates to systematically monitor, and, if deemed necessary, to respond to the policies and guidelines developed by other ALA groups. Nor is their any indication that these committees would tackle some of the other issues that I had raised, especially those concerning the ALA Accreditation Committee; no efforts seem to be afoot for lobbying the ALA Accreditation Committee to revisit its accreditation criteria.
Judged by the responses to several e-mail inquiries, neither the Accessibility Assembly nor LSSPS submitted formal comments about the proposed “Principles of Digitized Content” drafted by ALA-OITP's Task Force on Digitization Policy. Luckily, thanks to the input provided by other individuals, the final version, approved by ALA Council on June 15, fully acknowledges the needs of people with disabilities. The introductory “Values” section of the final document, renamed “Principles for Digital Content”, states that “equitable access to digital library materials is ensured through maximum accessibility, ubiquity, sustainability, and barrier-free access.” The final section emphasizes the need for suitable standards:
Interestingly, ALA Council also approved a second policy-type document: the Resolution on Accessible Digitization Projects, initiated by ASCLA. It appears that the drafting of these two different documents went on without the two respective committees taking notice of each other's efforts.
In my speech, I criticized ALA for not sending a strong and clear signal to database vendors that accessibility is important. While the Resolution on Accessible Digitization Projects does not address the accessibility of vendor-provided databases – it is concerned with the digital conversion of print materials (undoubtedly also extremely important), not with the proper rendering of born-digital resources – it could serve as a model for future policy statements directed at commercial database producers:
Resolved, that the ALA strongly encourage all libraries and other entities engaging in digitization projects to adopt Section 508 regulations to ensure that they are creating versions of materials that are accessible to persons using screen-reader or other assistive technologies; and, be it further Resolved, that ALA forward this resolution to other agencies and organizations that help libraries digitize their materials and that design access software, such as the Institute of Museum and Library Services and state library agencies, and to companies that work with libraries doing digitization project .
As for the revisions of ACRL's Guidelines for Distance Learning Library Services, not much appears to have happened since January 2007. The last change to the draft on ACRL's Distance Learning Section Wiki site was entered in December 2006. With a new chair person leading the Guidelines Committee, it is difficult to predict whether the revision process will speed up or slow down from what was previously anticipated. --------------------------------------------------------------------------------
Online references and notes
8. http://blogs.ala.org/digitizationprinciples.php?m=200702 (This version is either close or identical to the version referred to in the text.)
10. Simon Healy is a member of ASCLA’s Accessibility Assembly.
14. www.ala.org/ala/aasl/aboutaasl/aaslgovernance/aaslleadership/2007aaslannualboarddocs/ 22_DigitalContent.pdf
Comeaux, David and Axel Schmetzke, "Web Accessibility Trends in University Libraries and Library Schools." Library Hi Tech, 25(4), 2007: 457-477.
Walling, L.L. (2004), "Educating students to serve information seekers with disabilities."Journal of Education for Library and Information Science, 45 (2): 137-48.
About the author
Axel Schmetzke works as a Reference and Bibliographic Instruction Librarian at the University of Wisconsin-Stevens Point. He holds Master's-level degrees in communicative disorders, special education and library and information science, as well as a PhD in educational policy studies. In 2006, he received the ALA-ASCLA Francis Joseph Campbell Award. Axel Schmetzke can be contacted at: firstname.lastname@example.org.
First posted Dec. 7, 2007; slightly revised Dec. 8, 2007; slightly revised and updated Dec. 28, 2007.