Brian Schottlaender expressed the opinion that there might be less here than meets the eye. I have come to the same conclusion. However, there are a few points, some of which may be significant. So I offer the following comments as a contribution to CC:DA’s deliberations.

Most of the differences I found were just differences, not conflicts. For example, rules 9.7B7 and 12.7B7 address comparable issues on notes generally related to Area 2 of the description. However, while 9.7B7 is for notes on edition and history, 12.7B7 is on relationships (not just historical or chronological relationships) between the item described and other bibliographic resources. Different, but not in conflict. The reason why both chapters have to be applied to electronic integrating resources is that there are distinct rules needed to deal with the electronic and the integrating aspects of the resources. Most of the differences between the two chapters fall into this category, and I won’t bother to list them.

What remains are some rules that may not be compatible when applied to the same resources. I offer my own thoughts, which are usually questions, not recommendations. The basis for my comparison is the rule revision proposal for Chapter 12 and the ALA revision proposals for Chapter 9 as modified by JSC decisions. I generally work from Chapter 12 to Chapter 9, rather than the other way around.

• 12.0A/9.0A: Chapter 12 contains an explicit instruction to apply Chapter 9 to integrating electronic resources. Chapter 9 only contains a general instruction to apply other chapters as needed. It occurs to me that Chapter 9 would benefit from a more explicit statement regarding integrating resources.

  Further, one of the more difficult decisions that a cataloger of networked electronic resources needs to make is whether Chapter 12 applies, i.e., whether the resource is integrating. This is particularly true for resources on the World Wide Web. In conversation, Jean Hirons stated that there needs to be something more than the fact that the item in question is in a format that allows update. There needs to be some indication of an intent to update in an integrating manner. In the introduction to MARBI Discussion Paper No. 119, there is the following statement: “For purposes of this document, a Web site is defined as a collection of data, documents, and links to other sites on the World Wide Web that is generally updated over time.” Such sites are integrating, but the individual documents on the site may not be. These are useful guidelines, and something along these lines might or might not be appropriate for inclusion in AACR.

• 12.0B2/9.0B1: The two rules for determining the chief source of information embody dramatically different philosophies. 9.0B1 embodies the new approach endorsed by the Joint Steering Committee which takes a broad approach to sources of information: look anywhere within the resource for relevant information, use judgment in selecting the best source, give a note on the source of the title so that another cataloger can identify whether or not the description represents the same item. 12.0B2 is based on the need for sufficient guidelines that any two catalogers anywhere in the world will not only recognize that they are describing the same resource, but will choose the same chief source (and therefore the same title). The efforts to create a single set of conventions applied worldwide for defining and identifying a continuing resource depend on this level of detail. This difference in philosophy will need to be resolved somehow.

• 12.1B1 last paragraph: This rule for making a note on the source of the title for electronic resources makes a reference to 12.7B3. Should not the rule governing notes for electronic resources be in Chapter 9 — i.e., 9.7B3? If the basic rule is in 9.7B3, what should be done in 12.7B3?

• 12.1B3: This rule uses the term “home page” to refer to a particular location within an electronic resource. Chapter 9 (I think) carefully avoids using this term, because there is some disagreement about what it refers to. If this concept is needed in 12.1B3, should there not be something in Chapter 9 that gives the term its meaning and context?

• 12.1E1: This is a new rule that conflicts with 9.1E1 and with 1.1E1. The concept in 12.1E1 does represent an important principle of serials cataloging, a concept which an article I recently reviewed referred to as “future-orienting” — in other words, don’t load the bibliographic record with things that are likely to change unless they are really important. Is this conflict from 1.1E1 a problem?

• 12.1F1/9.1F1: 9.1F1 limits statements of responsibility to “persons or bodies credited with a major role in creating the content”; there is nothing comparable in 12.1F1, which simply refers back to 1.1F1. This is nothing new; that language has been in 9.1F1 from the outset.

• 12.2B4/9.2B1: 12.2B4 contains an instruction for “resources published in numerous editions”; 9.2B1 contains an instruction for “frequently updated remote access resources” and a reference to 9.2B8 for the instruction to make a note. Although the terminology is different in the two rules, they may be addressing the same phenomenon. In this case, it seems that the governing rule should be in Chapter 12, because this kind of updating is the essence of what makes a resource integrating.

• 12.7B and 9.7B both contain instructions to make notes in the order given. Each chapter follows the order of the ISBD areas, but each has a different set of notes to put first. Has this come up before? Is it a problem or can it be left to cataloger judgment?

• 12.7B17/9.7B17: 12.7B17 deals with notes on indexes; 9.7B17, with summary notes. However, 12.7B18, which deals with contents notes, includes instructions for making summary notes for electronic integrating resources and for loose-leaf publications. Shouldn’t there be separate rules for contents notes and for summary notes in Chapter 12?

• 1.7B23/9.7B23/12.7B23: These three rules all deal with notes identifying the item described. 1.7B23 is stated in terms of the issue, iteration, etc. described; 9.7B23, in terms of the date viewed (which may be equivalent to the iteration of an integrating resource); 12.7B23, in terms of the iteration but also in terms of the latest or earliest issue consulted. Are these rules compatible? Are the Chapter 9 and 12 rules an implementation of the Chapter 1 rule? Note also that 12.7B23 contains instructions about, and examples of, combining notes, a proposal which JSC rejected in the case of Chapter 9.

Short final issue: As yet there are no recommendations for how to integrate the new appendix into the rules. It might be a good idea to suggest some guidelines — or even propose the actual changes. Some thoughts:

• The basic reference to the Appendix needs to be very early in the rules. The decision about whether a new description is required is in fact a decision that the cataloger must make before beginning to describe an item. If the new Introduction to the rules is issued at the same time as the Appendix, the instruction should go there. If not, then something might be added to rule 0.3.

• Clearly rule 21.2A will have to be revised now that the substance has been removed to the Appendix.

• The other area that might related to the Appendix are the rules for Area 2 in the various chapters. There are definitely rules in, or proposed for, Chapter 9 that attempt to distinguish major and minor changes. There may be similar rules in other chapters.