I have worked in public libraries and library systems in Indiana, Minnesota, and Iowa for 30+ years. In both Indiana and Iowa, the regional systems are multi-type as permitted by state statute. In my experience, multi-type regional systems make much more sense than does Minnesota's current structure of two "layers" of systems, one for public libraries only and one for multi-type libraries, including public libraries. Multi-type systems reduce redundancy of operations in so many areas: administration, staffing, accounting, auditing, communication, budgeting, facilities, lobbying and legislative activities, governance, member support, training, information and education, travel, technical and telecommunications issues, and on and on. Having one system is much easier for legislators to comprehend and therefore leads to greater likelihood of political and financial support. Having one system is much easier for users and the general citizenry to comprehend and therefore leads to greater likelihood of political and financial support as well as participation/membership. One "layer" seems to make sense especially where the geographic area served by two "layers" is the same. Two "layers" of systems appears to be, and often is, cumbersome, confusing, redundant, and less cost-effective than just one. It was never my experience that any one type or size of library in these multi-type systems I participated in ever felt "superior" or "inferior" -- there was no sense of paranoia. On the contrary, cooperation among the multi-types seemed to actually be more likely since "turf" or size was not usually an issue. Everyone participated on the same footing. The goal was always mutual support regardless of who was helping whom, and that assistance often went both ways (from small to big library or from school to public library, etc, never just one way). I was never a part of any discussion while a member of these multi-type regions to consider breaking off into two "layers" such as now exist in Minnesota. I think the issue now under study to merge SELCO and SELS makes a great deal of sense. I don't see any practical, financial, or structural reasons not to. Regarding the question of whether special legislation should be necessary to accommodate such a merger, I think perhaps Minnesota statute is purposely vague for just such regional initiatives as this, so I tend to agree with the Commissioner of Education on that. But, if there is any potential political or financial or constituent risk to merge without special legislation, what about getting an opinion from the Attorney General's office on the matter before continuing the discussion?