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Have not done this in MODS, but in our bibliographic records we do this as 662 $b District of Columbia $d Washington, with $b being "First-order political jurisdiction" and $d being "City".  This is from the MARC 21 Format for Bibliographic Data.

Colleen
Colleen R. Cahill
Digital Conversion Coordinator
  & Recommending Officer of Fantasy and Science Fiction
Geography & Map Division
Library of Congress
101 Independence Ave, SE
Washington, DC 20540-4650
202-707-8540
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________________________________
From: Metadata Object Description Schema List [[log in to unmask]] On Behalf Of Elizabeth McKelvey [[log in to unmask]]
Sent: Monday, September 27, 2010 10:45 AM
To: [log in to unmask]
Subject: [MODS] Expressing Washington, DC

Hi,

Any suggestions on expressing Washington, DC in mods:hierarchicalGeographic?

We are doing a project to describe early American land records.

In most cases we are dealing with a state, so we do the following:
            <mods:subject>
                        <mods:hierarchicalGeographic>
                                    <mods:state>Massachusetts</mods:state>
                                    <mods:city>Boston</mods:city>
                        </mods:hierarchicalGeographic>
            </mods:subject>

In the TGN, District of Columbia is labeled as a “national district.”  And MARC has:
$b - First-order political jurisdiction (NR)
$c - Intermediate political jurisdiction (R)
which would work.

So, any thoughts on how to do Washington, DC in MODS?

Thanks,

Betsy


Betsy McKelvey
Digital Collections Librarian
617-552-1989