Environmental Protection
EPA Needs to Ensure That Best Practices and Procedures Are Followed When Making Further Changes to Its Library Network Gao ID: GAO-08-304 February 29, 2008Established in 1971, the Environmental Protection Agency's (EPA) library network provides staff and the public with access to environmental information. Its 26 libraries contain a wide range of information and resources and are located at headquarters, regional offices, research centers, and laboratories nationwide. In 2006, EPA issued a plan to reorganize the network beginning in fiscal year 2007. The plan proposed closing libraries and dispersing, disposing of, and digitizing library materials. GAO was asked to assess (1) the status of, and plans for, the network reorganization; (2) EPA's rationale for reorganizing the network; (3) the extent to which EPA has communicated with and solicited the views of EPA staff and external stakeholders in conducting the reorganization; (4) EPA's steps to maintain the quality of library services after the reorganization; and (5) how EPA is funding the network and its reorganization. For this study, GAO reviewed pertinent EPA documents and interviewed EPA officials and staff from each of the libraries.
Since 2006, EPA has implemented its reorganization plan to close physical access to 4 libraries. In the same period, 6 other libraries in the network decided to change their operations, while 16 have not changed. Some of these libraries have also digitized, dispersed, or disposed of their materials. Since the reorganization, EPA has begun drafting a common set of agencywide library procedures and has hired a program manager for the network. While these procedures are under development, however, EPA has imposed a moratorium on further changes to the network in response to congressional and other expressions of concern. EPA's primary rationale for the library network reorganization was to generate cost savings by creating a more coordinated library network and increasing the electronic delivery of services. However, EPA did not fully follow procedures recommended in a 2004 EPA study of steps that should be taken to prepare for a reorganization. In particular, EPA did not fully evaluate alternative models, and associated costs and benefits, of library services. EPA officials stated that they needed to act quickly to reorganize the library network in response to a proposed fiscal year 2007 funding reduction. EPA did not develop procedures to inform staff and the public on the final configuration of the library network, and EPA libraries varied considerably and were limited in the extent to which they communicated with and solicited views from stakeholders before and during the reorganization effort. In particular, EPA's plan did not include information that the Chemical Library was to close, and EPA did not inform staff or the public until after the fact. EPA's communication procedures were limited or inconsistent because EPA acted quickly to make changes in response to a proposed fiscal year 2007 funding reduction, and because of the decentralized nature of the library network. EPA is currently increasing its communication efforts. EPA does not have a post-reorganization strategy to ensure the continuity of library services and has not yet determined the full effect of the reorganization on library services. Moreover, EPA has recently made several changes that could have impaired user access to library materials and services. For example, EPA did not determine whether federal property management regulations applied to the dispersal and disposal of library materials before it closed the libraries. Furthermore, EPA lacked oversight of the reorganization process and does not have procedures that would allow the agency to measure performance and monitor user needs. Several different EPA offices are responsible for the libraries in the network. Each office generally decides how much funding to allocate to the libraries for which it is responsible and how to fund their reorganization. However, when faced with a proposed budget reduction of $2 million in fiscal year 2007, EPA specifically directed that these offices reduce funding for their libraries and did not specify how to achieve the reduction. Additional funds were not allocated to assist offices in closing their libraries.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-304, Environmental Protection: EPA Needs to Ensure That Best Practices and Procedures Are Followed When Making Further Changes to Its Library Network
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
February 2008:
Environmental Protection:
EPA Needs to Ensure That Best Practices and Procedures Are Followed
When Making Further Changes to Its Library Network:
GAO-08-304:
GAO Highlights:
Highlights of GAO-08-304, a report to congressional requesters.
Why GAO Did This Study:
Established in 1971, the Environmental Protection Agency‘s (EPA)
library network provides staff and the public with access to
environmental information. Its 26 libraries contain a wide range of
information and resources and are located at headquarters, regional
offices, research centers, and laboratories nationwide. In 2006, EPA
issued a plan to reorganize the network beginning in fiscal year 2007.
The plan proposed closing libraries and dispersing, disposing of, and
digitizing library materials.
GAO was asked to assess (1) the status of, and plans for, the network
reorganization; (2) EPA‘s rationale for reorganizing the network; (3)
the extent to which EPA has communicated with and solicited the views
of EPA staff and external stakeholders in conducting the
reorganization; (4) EPA‘s steps to maintain the quality of library
services after the reorganization; and (5) how EPA is funding the
network and its reorganization. For this study, GAO reviewed pertinent
EPA documents and interviewed EPA officials and staff from each of the
libraries.
What GAO Found:
Since 2006, EPA has implemented its reorganization plan to close
physical access to 4 libraries. In the same period, 6 other libraries
in the network decided to change their operations, while 16 have not
changed. Some of these libraries have also digitized, dispersed, or
disposed of their materials. Since the reorganization, EPA has begun
drafting a common set of agencywide library procedures and has hired a
program manager for the network. While these procedures are under
development, however, EPA has imposed a moratorium on further changes
to the network in response to congressional and other expressions of
concern.
EPA‘s primary rationale for the library network reorganization was to
generate cost savings by creating a more coordinated library network
and increasing the electronic delivery of services. However, EPA did
not fully follow procedures recommended in a 2004 EPA study of steps
that should be taken to prepare for a reorganization. In particular,
EPA did not fully evaluate alternative models, and associated costs and
benefits, of library services. EPA officials stated that they needed to
act quickly to reorganize the library network in response to a proposed
fiscal year 2007 funding reduction.
EPA did not develop procedures to inform staff and the public on the
final configuration of the library network, and EPA libraries varied
considerably and were limited in the extent to which they communicated
with and solicited views from stakeholders before and during the
reorganization effort. In particular, EPA‘s plan did not include
information that the Chemical Library was to close, and EPA did not
inform staff or the public until after the fact. EPA‘s communication
procedures were limited or inconsistent because EPA acted quickly to
make changes in response to a proposed fiscal year 2007 funding
reduction, and because of the decentralized nature of the library
network. EPA is currently increasing its communication efforts.
EPA does not have a post-reorganization strategy to ensure the
continuity of library services and has not yet determined the full
effect of the reorganization on library services. Moreover, EPA has
recently made several changes that could have impaired user access to
library materials and services. For example, EPA did not determine
whether federal property management regulations applied to the
dispersal and disposal of library materials before it closed the
libraries. Furthermore, EPA lacked oversight of the reorganization
process and does not have procedures that would allow the agency to
measure performance and monitor user needs.
Several different EPA offices are responsible for the libraries in the
network. Each office generally decides how much funding to allocate to
the libraries for which it is responsible and how to fund their
reorganization. However, when faced with a proposed budget reduction of
$2 million in fiscal year 2007, EPA specifically directed that these
offices reduce funding for their libraries and did not specify how to
achieve the reduction. Additional funds were not allocated to assist
offices in closing their libraries.
What GAO Recommends:
GAO recommends that EPA continue its moratorium until it takes
corrective actions to (1) justify its decision to reorganize the
network, (2) improve its outreach efforts, (3) ensure sufficient
oversight and monitoring of the reorganization, and (4) implement
procedures for the proper dispersal and disposal of library materials.
EPA agreed with GAO‘s recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-304]. For more information, contact John
B. Stephenson at (202) 512-3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Some Libraries Independently Decided to Close, Reduce Their Hours, or
Take Other Actions, but the Final Network Configuration Is Still
Uncertain:
EPA Did Not Effectively Justify Its Decision to Reorganize Its Library
Network:
EPA Did Not Fully Inform or Solicit Views from the Full Range of
Stakeholders on the Reorganization but Is Now Increasing Its Outreach
Efforts:
EPA Lacks a Strategy to Ensure Continuity of Library Services and Does
Not Know Whether Its Actions Have Impaired Access to Environmental
Information:
EPA Program Offices Are Responsible for Funding Their Libraries and
Their Reorganization Through Their Support Budgets:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Key Practices and Implementation Steps for Effective
Mergers and Organizational Transformations:
Appendix III: Comments from the Environmental Protection Agency:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Operating Status of Each Library in the EPA Library Network:
Table 2: Current Status of Materials at Closed Libraries:
Table 3: General Location of Most of the Dispersed Materials from
Closed Libraries:
Figures:
Figure 1: Timeline of EPA Library Network Assessments and Planning
Efforts and Reorganization Activities:
Figure 2: Boxed-up Books from the Region 5 Library Now on Shelves in
the Headquarters Repository Library:
Abbreviations:
EPA: Environmental Protection Agency:
GSA: General Services Administration:
NEPIS: National Environmental Publications Internet Site:
OARM: Office of Administration and Resources Management:
OEI: Office of Environmental Information:
OLS: Online Library System:
OPPTS: Office of Prevention, Pesticides, and Toxic Substances:
ORD: Office of Research and Development:
[End of section]
United States Government Accountability Office: Washington, DC 20548:
February 29, 2008:
Congressional Requesters:
The Environmental Protection Agency's (EPA) library network provides
access to critical environmental information that the agency needs to
promote environmental awareness, conduct research, enforce
environmental laws, make policy decisions, and fulfill its mission of
protecting human health and the environment. In fiscal year 2006, the
network included 26 libraries across headquarters, regional offices,
research centers, and laboratories that were independently operated by
several different EPA program offices, depending on the nature of the
libraries' collections.[Footnote 1] The combined network collection
contains information on a spectrum of issues, including environmental
protection and management, sciences, legislative mandates on
environmental matters, and specialized regional or program office
topics. The network provides this information and research support to
assist EPA staff in performing their work. EPA enforcement staff, for
example, use the libraries to obtain scientific and technical
information to support the development of enforcement cases and to
conduct research on legal and business issues. The library network also
provides information and services to state environmental agencies,
local community organizations, and the general public to help these
stakeholders in protecting human health and the environment.
In fiscal year 2007, EPA began to reorganize its library network on the
basis of a 2006 reorganization plan issued by EPA's Office of
Environmental Information (OEI) that focused on its headquarters
library and the 10 regional office libraries. In addition to these 11
libraries, the network included 15 libraries located in EPA
laboratories or in other EPA program offices, such as the Office of
Prevention, Pesticides, and Toxic Substances (OPPTS). Funding for the
OEI headquarters and regional office libraries account for about 36
percent of the funding spent on library activities in fiscal year 2006.
The 2006 plan--EPA FY 2007 Library Plan: National Framework for the
Headquarters and Regional Libraries--and the reorganization were
accelerated by a proposed $2 million budget reduction for the OEI
libraries based on the President's fiscal year 2007 budget
request.[Footnote 2] The plan was intended to provide a framework on
how to consolidate libraries and make more materials and services
available online. As such, the plan proposed a phased approach to
closing physical access to some libraries and the creation of Library
Centers of Excellence to provide library services on specific issue
areas, while continuing to ensure access to library services and
information for EPA staff and the public.[Footnote 3] It stated that 3
regional libraries, located in Chicago, Dallas, and Kansas City, would
close and that their collections would be dispersed to other EPA or non-
EPA libraries, disposed of, or digitized and made available online. The
plan also proposed that a headquarters library, managed by OEI, would
close physical access but would serve as one of EPA's three
repositories for storing EPA's hard copy collections.[Footnote 4] Under
the plan, EPA staff and the public would not have walk-in access to
collections at the closed headquarters or regional office libraries,
but they would continue to have access to reports and documents
electronically or hard copy access via interlibrary loan. EPA staff
would also be able to obtain research and reference assistance from
librarians provided by their library or by a Center of Excellence
through a service agreement.
With the reorganization of the EPA library network, Congress,
professional library associations, and others have raised concerns
regarding how such changes will affect the delivery of information that
is critical to fulfilling EPA's mission. In general, their concerns
focus on several procedural aspects of the reorganization effort. These
include the closing of libraries or reducing their hours of operation;
the rationale for reorganizing the library network in the first place;
the procedures used in dispersing, disposing of, and digitizing library
materials; steps being taken to guard against potential degradation of
library services; and the availability of resources to enable the
libraries to continue meeting their missions.
In this context, you asked us to obtain and analyze information
relevant to these concerns. Specifically, you asked that we (1)
determine the status of, and plans for, the library network
reorganization; (2) evaluate EPA's rationale for its decision to
reorganize the library network; (3) assess the extent to which EPA has
communicated with and solicited views from EPA staff and external
stakeholders in planning and implementing the reorganization; (4)
evaluate the steps EPA has taken to maintain the quality of library
services following the reorganization, both currently and in the
future; and (5) determine how EPA is funding the library network and
its reorganization.
To address these objectives, we reviewed relevant EPA documents,
policies, plans, and guidance as well as related laws and requirements
pertinent to the library network and reorganization effort. To
determine key practices for change management, we assessed EPA's
reorganization effort against our past work on key practices and
implementation steps to assist mergers and organizational
transformations.[Footnote 5] We interviewed EPA librarians and library
managers from each of the 26 libraries in EPA's library network as well
as EPA officials knowledgeable about EPA's library network and budget.
In addition, we interviewed representatives from local unions, who
represent EPA staff, and regional science councils, which is a group
that consists of EPA scientists and technical specialists. We also
sought information from library professionals, including
representatives from the American Library Association and the
Association of Research Libraries; members of academia; and private
consulting companies with expertise in libraries. Appendix I provides a
detailed discussion of our objectives, scope, and methodology.
We conducted this performance audit from December 2006 through February
2008 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Results in Brief:
Since 2006, EPA has implemented its library reorganization plan to
close physical access to the OEI headquarters library and 3 regional
office libraries. In the same period, 6 other libraries in the network
independently decided to change their operations: 1 closed, 4 reduced
their hours of operation, and 1 changed the way it provides library
services. Sixteen libraries have not changed. Furthermore, some of
these libraries have digitized, dispersed, or disposed of their
materials. The reorganization effort has largely been decentralized:
that is, the EPA program or regional office responsible for each
library independently decided what types of changes to make. Since
implementing the reorganization, EPA has begun drafting a common set of
agencywide library procedures and has hired a program manager for the
library network. While these procedures are under development, however,
EPA has imposed a moratorium on further changes to the library network
in response to congressional and other concerns. EPA officials told us
that the agency wants to refine its library procedures, among other
things, before lifting the moratorium, but it has not set a date for
completing these refinements. The future of the library network, its
configuration, and its operations may be contingent on (1) the
completion of its library procedures; (2) EPA's response to directions
accompanying its fiscal year 2008 appropriation to use $1 million to
restore libraries recently closed; and (3) EPA's 2008 library plan,
which describes how EPA expects to operate the library network in the
future. At the time of our review, EPA was drafting its 2008 library
plan and had not yet submitted a report to the Senate and House
Committees on Appropriations on how the agency will restore the EPA
library network per the fiscal year 2008 appropriations act.
EPA's primary rationale for reorganizing its library network was to
generate cost savings by creating a more coordinated library network
and increasing the electronic delivery of services. However, EPA did
not effectively justify its decision to reorganize the library network
because it did not implement a process for conducting a number of
analyses, including many that were recommended in its own study of the
libraries prior to initiating the reorganization. According to this
2004 internal study, the library network was generally cost-effective
but could be improved with a reorganization that followed certain
recommended actions. To make a more informed decision on how best to
reorganize, the study recommended that EPA first, among other things,
survey EPA staff who use the libraries, review and revise the policy
and procedures that guide the library network, and develop and review
alternative models of library services. However, EPA did not fully
implement these steps. In addition, Office of Management and Budget
guidance recommends that agencies conduct a benefit-cost analysis to
support decisions to initiate, renew, or expand programs or projects,
and that, in conducting such an analysis, tangible and intangible
benefits and costs be identified, assessed, and reported. However, EPA
did not perform a benefit-cost analysis in this case. According to EPA
officials, OEI decided to reorganize its libraries without completing
the recommended analyses because it wanted to reduce its fiscal year
2007 funding by $2 million to create the savings necessary for its
headquarters library and the regional office libraries per the
President's budget proposal.
EPA did not develop procedures to inform the full range of stakeholders
on the final configuration of the library network, and EPA libraries
varied considerably in the extent to which they communicated with and
solicited views from staff, external stakeholders, and experts before
and during the reorganization. Such efforts were limited or
inconsistent because EPA acted quickly to make changes in response to a
proposed fiscal year 2007 funding reduction and because of the
decentralized nature of the library network. As we have previously
reported,[Footnote 6] an organization's transformation or merger is
strengthened when it sets and makes public implementation goals and an
outline; establishes a communication strategy by communicating early
and often to build trust, ensuring consistency of message, and
involving staff to obtain their ideas and gain ownership for the
transformation; and adopts leading practices to build a world-class
organization. In the case of the library network reorganization, EPA
did not do the following:
1. Inform stakeholders on how the final library network would be
configured or the implementation goals and timeline that it would take
to achieve this final configuration. For example, EPA's library plan
did not include information that the Chemical Library was to close, and
EPA did not inform staff or the public that the library was to close
until after the fact. The lack of transparency in the reorganization
process could result in a lack of support for the effort.
2. Have an agencywide communication strategy for the reorganization
effort and, as a result, did not conduct outreach activities
consistently across libraries or conducted them in a limited fashion.
For example, only a few of the regional libraries solicited staff views
through discussions with union representatives. EPA also did not
generally solicit the views of the public and library associations.
Without an agencywide communication strategy, staff ownership for the
changes may be limited, staff may be confused about the changes, and
EPA cannot be sure the changes are meeting the needs of EPA staff and
external stakeholders.
3. Solicit views from experts to obtain information on leading
practices for library services. As such, EPA cannot be sure that it is
using leading practices in its effort to reorganize the network.
EPA officials are currently reaching out to stakeholders, including EPA
staff and library experts, by holding and attending stakeholder
meetings and conferences.
EPA does not have an effective strategy to ensure the continuity of
library services following the reorganization and does not know the
full effect of the reorganization on library services. According to our
review of key practices and implementation steps to assist mergers and
organizational transformations, organizations that are undergoing
change should seek and monitor staff attitudes and take appropriate
follow-up actions. EPA's library plan describes the reorganization
effort as a "phased approach," but it does not provide specific goals,
timelines, or feedback mechanisms that allow the agency to measure
performance and monitor user needs to ensure a successful
reorganization while maintaining quality services. To balance the
continued delivery of services with merger or transformation
activities, we have also found that it is essential to ensure that top
leadership drives the transformation. However, EPA lacked a national
program manager for the library network to oversee and guide the
reorganization effort, and each library decided whether to close and
how to disperse and dispose of library materials. EPA did not choose to
follow such key practices for a successful transformation, even though
the agency made several changes to the library network that could have
impaired the continued delivery of library materials and services to
its staff and the public. For example, service agreements were not
fully tested in advance to determine their effectiveness. Furthermore,
EPA did not determine whether federal property management regulations
applied to the dispersal and disposal of library materials before it
closed the libraries. In the absence of such a determination, EPA
provided vague criteria and guidance to its libraries without
adequately overseeing the process.
The several different program offices responsible for the EPA libraries
in the network each decide how much of their available funding to
allocate to their libraries and how to fund their reorganization. For
example, OEI typically provides funding for the regional office
libraries through each region's support budget, and gives regional
management discretion on how to allocate this funding among the library
and other support services on the basis of the needs and priorities in
the region. However, when faced with a proposed budget reduction of $2
million in fiscal year 2007, rather than following its normal
procedures by giving regional office and headquarters managers
discretion on how to allocate their budgets, OEI specifically directed
the regional and headquarters offices to reduce funding for OEI
libraries--a reduction of 77 percent for these libraries from the
previous fiscal year. EPA did not specifically allocate funds to help
closing libraries manage their collections; instead, the program or
regional office responsible for the libraries used its annual funding
to pay for these costs. Services formerly provided by the closed
libraries are now provided on a fee-for-service basis by other
libraries in the network. Regarding the costs of the reorganization,
OEI and OPPTS did not track the costs associated with closing the
libraries, such as boxing, shipping, and digitizing materials. However,
EPA estimated that it spent about $80,000 to digitize 15,260 titles
between December 2006 and January 2007. This effort was funded by the
Office of Administration and Resources Management (OARM) under an
already existing contract.
In light of these findings, we are recommending that the Administrator
of EPA continue the agency's moratorium on changes to the library
network until the agency (1) develops a strategy to justify its
reorganization plans; (2) improves its outreach efforts; (3) ensures
sufficient oversight and control over the reorganization process, and
continuously and consistently monitors the impact of the reorganization
on EPA staff and the public; and (4) implements procedures ensuring
that library materials are dispersed and disposed of consistently and
in accordance with federal property management regulations.
Background:
Soon after the creation of EPA, the library network was formed to
provide staff and the public with access to environmental information
in support of EPA's mission to protect human health and the
environment. Established in 1971, the network is composed of libraries
and repositories located in the agency's headquarters, regional
offices, research centers, and laboratories throughout the country. The
combined network collection contains a wide range of general
information on environmental protection and management; basic and
applied sciences, such as biology, chemistry, engineering, and
toxicology; and extensive coverage of topics featured in legislative
mandates, such as hazardous waste, drinking water, pollution
prevention, and toxic substances. Several of the libraries maintain
collections that are focused on special topics to support specific
regional or program office projects. As such, the libraries differ in
function, scope of collections, extent of services, and public access.
During this period, EPA's library network operations were guided by
EPA's Information Resources Management Policy Manual. Chapter 12 of the
policy manual stipulated that the library network provide EPA staff
with access to information to carry out the agency's mission, and that
the libraries provide state agencies and the public with access to the
library collection. Chapter 12 also established the role of the
national program manager with responsibility for coordinating major
activities of the EPA library network. A national program manager
within OEI is responsible for coordinating the major activities of the
EPA library network. The role of the national program manager is to
work with the library network and its managers to provide several
essential services, such as assessing the needs of program staff and
providing services to meet those needs. Unlike other national program
manager positions at EPA, the national program manager for the library
network does not have budget authority for the libraries.
Before the 2007 reorganization, 26 libraries comprised the library
network, each funded and managed by several different program offices
at EPA:[Footnote 7] 1 library was managed by OEI, 10 libraries were
managed by regional offices,[Footnote 8] 8 libraries were located at
EPA laboratories within the Office of Research and Development (ORD),
and 2 libraries were located within OARM. In addition, each of the
following program offices had 1 library: Office of the Administrator,
Office of General Counsel, OPPTS, Office of Enforcement and Compliance
Assurance, and Office of Air and Radiation.
In addition to its physical locations and holdings, the EPA network
provides access to its collections through a Web-based database of
library holdings--the Online Library System (OLS)--that is known as
EPA's online "card catalog." OLS enables EPA staff and the public to
search for materials in any of the EPA libraries across the country
that are part of the network. According to EPA estimates, the combined
EPA collection in 2003 included 504,000 books and reports; 3,500
journals; 25,000 maps; and 3,600,000 information objects on microfilm.
If an item is not available on-site to EPA staff or the public, it is
made available through interlibrary loan from another library within
the network or another public library. Up to 26,000 of these EPA
documents are available electronically to EPA staff and the public
through a separate online database--the National Environmental
Publications Internet Site (NEPIS). In addition, EPA staff have access
to over 120,000 information sources--such as online journals, the
Federal Register, news, databases of bibliographic information, and
article citations--from their desktop computers.
Librarians are available to assist EPA staff and the public, and, as of
March 2007, professional librarian staff accounted for just over 36
full-time-equivalent employees. In addition to these 6 federal
librarians and 30 contract librarians, several other staff, such as
technical specialists and library technicians, also work at the
libraries. Library staff provide a number of services to both EPA staff
and the public, including (1) support for EPA scientists and technical
staff, such as responding to quick and extended reference questions,
conducting literature and database searches, and providing training to
EPA staff on how to conduct their own searches; (2) support for EPA
enforcement staff, such as conducting legal or business research and
providing scientific and technical information to support enforcement
cases; (3) collection cataloging and maintenance; and (4) support for
the general public, such as answering quick and extended reference
questions, and providing training on how to search EPA databases. In
fiscal year 2005, the services provided to EPA staff by librarians at
OEI headquarters and regional office libraries included 41,029 quick
and extended reference checks, 8,286 interlibrary loans, and 85,226
database and literature searches. These librarians also provided EPA
staff with 52,975 resources, such as books and journal articles.
Beginning in 2003, EPA conducted a business case assessment of its
library network and a study of options for future regional library
operations. These two studies,[Footnote 9] which primarily focused on
the OEI headquarters library and the regional office libraries, were
intended to determine the value of library services and inform
management in the regions of their options to support library services
beyond fiscal year 2006. In August 2005, regional management formed a
Library Network Workgroup, composed of regional and headquarters
library managers as well as library managers from OARM and the National
Environmental Investigations Center libraries, to review the two
reports and develop recommendations on ways to maintain an effective
library network if the library support budget were reduced. The
workgroup issued its internal report, EPA Library Network: Challenges
for FY 2007 and Beyond, in November 2005.
After the Library Network Workgroup's report was issued, EPA
established a Library Steering Committee, composed of senior managers
from EPA's program offices and regions, to develop a new model for
providing library services to EPA staff. As such, the steering
committee reviewed the recommendations made by the workgroup and, in
August 2006, issued the EPA FY 2007 Library Plan: National Framework
for the Headquarters and Regional Libraries. See figure 1 for a
timeline of the assessments and planning efforts that EPA conducted and
library network reorganization activities.
Figure 1: Timeline of EPA Library Network Assessments and Planning
Efforts and Reorganization Activities:
[See PDF for image]
The following information is provided in the timeline:
Date: January 2004;
Assessments and planning efforts: Published: Business Case for
Information Services: EPA‘s Regional Libraries and Centers.
Date: September 2004;
Closures/reduction in hours: Region 2‘s Edison, NJ, library closed.
Date: June 2005;
Assessments and planning efforts: Published: Optional Approaches to
U.S. EPA Regional Library Support.
Date: July 2005;
Event: EPA identifies $2 million reduction for OEI headquarters and
regional office libraries in fiscal year 2007 straw budget.
Date: November 2005;
Assessments and planning efforts: Published: EPA Library Network:
Challenges for FY 2007 and Beyond.
Date: January 2006;
Closures/reduction in hours: Region 9 library reduces hours of
operation.
Date: February 2006;
Closures/reduction in hours: Region 3‘s Ft. Meade, MD, library closed to
the public;
Event: President‘s FY 2007 budget proposal released.
Date: May 2006;
Closures/reduction in hours: Region 10 library reduces hours of
operation.
Date: June 2006;
Closures/reduction in hours: Region 1 library reduces hours of
operation.
Date: August 2006;
Assessments and planning efforts: Published: EPA FY 2007 Library Plan:
National Framework for the Headquarters and Regional Libraries;
Closures/reduction in hours: OPPTS Chemical Library closed; Region 5
library closed;
Events: Service agreement established between Region 5 and Cincinnati
library.
Date: September 2006;
Events: Service agreement established between: Region 4 and Cincinnati
library; Region 6 and RTP[A] library; Region 7 and RTP/Region 3
libraries.
Date: October 2006;
Closures/reduction in hours: Region 6, Region 7, and OEI headquarters
libraries closed; OEI headquarters library converted into a repository.
Events: Service agreement established between ORD‘s National Center for
Environmental Assessment (Washington Offices) and RTP library.
Date: December 2006;
Closures/reduction in hours: Region 2 library reduces hours of
operation;
Events: Service agreement established between OEI‘s headquarters
library and RTP library[B].
Date: January 2007;
Events: 90-day moratorium on further changes to EPA libraries
instituted; Deadline to digitize all unique EPA documents from closed
libraries.
Date: February 2007;
Events: 90-day moratorium extended until further notice.
Date: April 2007;
Events: EPA library network interim policy finalized.
Source: GAO analysis of EPA data.
[A] "RTP" denotes Research Triangle Park, North Carolina.
[B] This service agreement, according to OPPTS officials, also provides
services to OPPTS and other EPA staff affected by the closure of the
Chemical Library.
[End of figure]
The August 2006 library plan provided the framework for the network to
begin reorganizing in the summer of 2006 in preparation for the
proposed fiscal year 2007 budget reduction beginning in October 2006.
(In September 2004, a Region 2 laboratory library in Edison, New
Jersey, closed, and a Region 3 laboratory library in Fort Meade,
Maryland, closed access to the public in February 2006.) The plan
describes a "phased approach" to disperse and dispose of library
materials in the libraries that will close. The plan also provided
guidelines for EPA staff to determine how the collections are to be
managed. According to the plan, OEI libraries in Regions 5, 6, and 7
would close and the headquarters library would close physical access to
its collection but would function as one of three repository libraries.
OARM libraries located in Cincinnati, Ohio, and Research Triangle Park,
North Carolina, would serve as the other two repositories. In addition,
according to the plan, EPA is developing Library Centers of Excellence,
where a library with more expertise in a specific area of reference
research would provide that service to staff in other regions.
Members of Congress and congressional committees, library professional
associations, public interest groups, and individuals have expressed
several concerns about the reorganization of the library network.
Specifically:
* During the reorganization, several Members of Congress submitted
letters to EPA and to the President asking to restore funding or asking
for specific information regarding the reorganization.
* In a February 2006 letter, representatives of 4 library associations
asked the House Committee on Appropriations to restore the budget cuts
to the library network and to require EPA to develop an information
management strategy.
* In a June 2006 letter, the presidents of 16 local unions,
representing over 10,000 EPA scientists, engineers, and environmental
protection specialists, protested the budget cut to the library network
to the Senate Committee on Appropriations.
* In August 2006, the American Federation of Government Employees
National Council of EPA Locals filed a formal grievance, requesting
that negotiations be held with the union regarding the library network
reorganization.[Footnote 10]
Some Libraries Independently Decided to Close, Reduce Their Hours, or
Take Other Actions, but the Final Network Configuration Is Still
Uncertain:
As a part of EPA's 2006 reorganization effort, some EPA libraries have
closed, reduced their hours of operation, or changed the way that they
provide library services. Furthermore, some of these libraries have
digitized, dispersed, or disposed of their materials. As noted in EPA's
August 2006 library plan, 1 OEI headquarters library closed and 3
regional office libraries closed; but during the same period, 6 other
libraries in the network independently decided to change their
operations--1 closed, 4 reduced their hours of operation, and 1 changed
the way that it provides library services. Sixteen EPA libraries have
not changed. During the reorganization effort, each of the libraries in
the network made its own decision on how it would manage its
collection--some digitized, or have plans to digitize, some of their
materials; some dispersed their materials to EPA and non-EPA libraries;
and some disposed of their materials. After making these changes, EPA
has begun to develop a common set of agencywide policies and procedures
for the library network. EPA is waiting to complete these policies and
procedures before lifting a moratorium on further change. The future of
EPA's library network--its configuration and its operations--are
contingent on the final policies and procedures, on EPA's response to
directions accompanying its fiscal year 2008 appropriation, and on
EPA's 2008 library plan.
Some Libraries Independently Decided to Close, and Others Reduced Their
Hours or Changed the Way That They Provided Library Services:
Due to the decentralized nature of the EPA library network, each
library decided on its own whether to close, reduce hours of operation,
change the way that it provided library services, or make no changes in
order to prepare for a proposed budget reduction. As table 1 shows, 4
libraries--as noted in EPA's library plan--closed physical access to
their libraries. Furthermore, 1 additional library in the network
closed, 4 reduced their hours of operation, and 1 changed the way that
it provides library services. However, these changes were not noted in
EPA's library reorganization plan. Sixteen libraries in the network did
not institute any changes.
Table 1: Operating Status of Each Library in the EPA Library Network:
Program office: Office of Environmental Information;
Library/Location: Headquarters Library/Washington, DC;
Operating status of library: Closed physical access; Serves as a
repository library.
Program office: Regional Office;
Library/Location: Region 1 Library/Boston, MA;
Operating status of library: Reduced hours of operation.
Program office: Regional Office;
Library/Location: Region 2 Library/New York, NY;
Operating status of library: Program office: Reduced hours of
operation[A].
Program office: Regional Office;
Library/Location: Region 3 Library/Philadelphia, PA;
Operating status of library: Program office: Open[B].
Program office: Regional Office;
Library/Location: Region 4 Library/Atlanta, GA;
Operating status of library: Program office: Open; Changed the way that
library services are provided.
Program office: Regional Office;
Library/Location: Region 5 Library/Chicago, IL;
Operating status of library: Program office: Closed physical access[C].
Program office: Regional Office;
Library/Location: Region 6 Library/Dallas, TX;
Operating status of library: Program office: Closed physical access[C,
D].
Program office: Regional Office;
Library/Location: Region 7 Library/Kansas City, KS;
Operating status of library: Program office: Closed physical access[D].
Program office: Regional Office;
Library/Location: Region 8 Library/Denver, CO;
Operating status of library: Program office: Open.
Program office: Regional Office;
Library/Location: Region 9 Library/San Francisco, CA;
Operating status of library: Program office: Reduced hours of operation.
Program office: Regional Office;
Library/Location: Region 10 Library/Seattle, WA;
Operating status of library: Reduced hours of operation.
Program office: Office of Prevention, Pesticides, and Toxic Substances;
Library/Location: Chemical Library/Washington, DC;
Operating status of library: Closed physical access[C].
Program office: Office of Administration and Resources Management;
Library/Location: Andrew Breidenbach Environmental Research Center/
Cincinnati, OH;
Operating status of library: Open; Serves as a repository library.
Program office: Office of Administration and Resources Management;
Library/Location: Research Triangle Park Library Service/Research
Triangle Park, NC;
Operating status of library: Open; Serves as a repository library.
Program office: Office of Enforcement and Compliance Assurance;
Library/Location: National Enforcement Investigations Center
Environmental Forensics Library/Denver, CO;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/Location: Environmental Sciences Division Technical Research
Center/Las Vegas, NV;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/Location: Ecosystem Research Division Library/Athens, GA;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Atlantic Ecology Division Library/Narragansett, RI;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Gulf Ecology Division Library/Gulf Breeze, FL;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Mid-continent Ecology Division Library/Duluth, MN;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Western Ecology Division Library/Corvallis, OR;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Ground Water and Ecosystems Restoration Division
Library/Ada, OK;
Operating status of library: Program office: Open.
Program office: Office of Research and Development;
Library/Location: Atmospheric Sciences Modeling Division Library/
Research Triangle Park, NC;
Operating status of library: Open[E].
Program office: Office of the Administrator;
Library/Location: Legislative Reference Library/Washington, DC;
Operating status of library: Open.
Program office: Office of General Counsel;
Library/Location: Law Library/Washington, DC;
Operating status of library: Open.
Program office: Office of Air and Radiation;
Library/Location: National Vehicle and Fuel Emissions Laboratory
Library/Ann Arbor, MI;
Operating status of library: Open.
Source: GAO analysis of EPA data.
[A] A library located at an Edison, New Jersey, laboratory in Region 2
closed in September 2004. This library closure preceded the closures
associated with the fiscal year 2007 library network reorganization.
Although this library was managed separately and independently from the
Region 2 library, the materials from this library were transferred to
the main Region 2 library in New York, New York, when the library
closed. Librarians from the main library in Region 2 now provide
library services to Edison, New Jersey, staff.
[B] The lone librarian in Region 3's satellite library in Ft. Meade,
Maryland, resigned in February 2006. The Ft. Meade library's collection
remains in place and is open for EPA staff use, although no staff
manage the collection. Librarians from the main library in Region 3,
located in Philadelphia, Pennsylvania, now provide library services to
Ft. Meade staff. According to EPA officials, the Ft. Meade library was
closed to the public because the library did not receive many visits
from the public, and because the library was located at a high-security
military base.
[C] The libraries in Regions 5 and 6 and the Chemical Library reduced
their hours of operation for a period of time prior to closing.
[D] The libraries in Regions 6 and 7, although closed to physical
access, still contain library materials on shelves because of the
moratorium on further changes to the network that was placed in January
2007. According to EPA officials, materials from the Regions 6 and 7
libraries are not accessible to walk-in traffic but remain accessible
through interlibrary loan.
[E] The Atmospheric Sciences Modeling Division library was funded by
the National Oceanic and Atmospheric Administration but run jointly by
ORD through an interagency agreement. The library materials for this
library are located at Research Triangle Park, North Carolina, and
managed by OARM library staff. In fiscal year 2008, the library was not
funded and will be consolidated into the OARM Research Triangle Park
library once the moratorium is lifted, according to EPA officials.
[End of table]
EPA's August 2006 library plan notes that three regional libraries--
Regions 5 (Chicago), 6 (Dallas), and 7 (Kansas City)--and the
headquarters library in Washington, D.C., would close physical access
to their libraries. In addition, OPPTS officials decided to close the
Chemical Library; however, this closure was not noted in the plan.
According to EPA officials, the plan focused on the OEI headquarters
and regional office libraries, and they did not think it was necessary
to reflect changes that were planned for other libraries. The focus of
the plan, according to EPA officials, was to set the framework on how
library services would be provided electronically and not on what
physical changes in the network were to occur. Although no longer
accessible to walk-in traffic from EPA staff and the public, the closed
regional and headquarters libraries continue to provide library
services, such as interlibrary loans and research/reference requests,
to EPA staff through service agreements that the closed libraries
established with libraries managed by OARM--located in Cincinnati,
Ohio, or Research Triangle Park, North Carolina--or with the Region 3
library located in Philadelphia, Pennsylvania.[Footnote 11] Service
agreements have been established between (1) the Cincinnati library and
Region 5, (2) the Research Triangle Park library and headquarters as
well as Regions 6 and 7, and (3) Region 3 and Region 7.[Footnote 12]
According to OPPTS officials, library services are provided to OPPTS
staff through a service agreement that the headquarters library has
established with the Research Triangle Park library, although OPPTS is
not a signatory to the service agreement. The library plan noted that
the public would access materials previously held by the closed
regional and headquarters libraries, either electronically using NEPIS,
a database of electronic EPA publications, or physically using
interlibrary loan.
For the regional libraries that had closed, their library spaces remain
unused. The Region 5 library space is empty, with all of its shelving
and furniture sold through a General Services Administration (GSA)
auction for $327. According to Region 5 officials, the space is
occasionally used for meetings, but no plans have been made on how the
space will be used. Many of the library materials remain on shelves in
Regions 6 and 7 because of the moratorium. According to a Region 7
official, because the library space is not being maintained, some of
its shelving has been removed and used for other purposes. EPA
officials noted that they plan to use the headquarters and Chemical
Library spaces for the headquarters repository, which would house
repository materials and the Chemical Library collection (see fig. 2
for a photograph of boxed-up books from the Region 5 library, now
located at the headquarters repository library). However, the library
space in the Chemical Library is currently being used as office space,
although nearly half of the space is devoted to shelving that cannot be
removed because it is considered historical.
Figure 2: Boxed-up Books from the Region 5 Library Now on Shelves in
the Headquarters Repository Library:
[See PDF for image]
This figure is a photograph of boxed-up books from the Region 5 Library
now on shelves in the Headquarters Repository Library.
Source: GAO.
[End of figure]
Of the four regional libraries that decided to reduce their hours of
operation, Regions 9 and 10 reduced their hours by about 30 percent,
and Regions 1 and 2 reduced their hours by more than 50 percent. The
library plan did not note that these libraries would be reducing their
hours. As we have previously noted, the focus of the plan, according to
EPA officials, was to set the framework on how library services would
be provided electronically and not on what physical changes in the
network were to occur. As such, EPA officials stated that they did not
think it was necessary to list in the plan which libraries were
planning on reducing hours.
Also, as noted in table 1, the Region 4 library changed the way that it
provided library services to its regional staff. While the library is
accessible to EPA staff and the public, and materials remain in place,
the library reduced the number of on-site contract librarians and
established a service agreement with the OARM library in Cincinnati,
Ohio, to provide Region 4 EPA staff with some core library services.
These core services include interlibrary loans, cataloging, online
literature searches, and reference and research requests. There is
currently one full-time professional federal librarian located at the
Region 4 library. The library plan did not note that Region 4 would
change the way that it provides library services to its staff and the
public.
Each EPA Library Independently Decided Which Materials Should Be
Selected for Digitization, Dispersal, or Disposal:
As part of the library reorganization, each library in the network that
was planning to close access to walk-in services independently decided
which materials would be retained at their library or be selected for
digitization, dispersal to EPA or non-EPA libraries, or disposal. To
assist libraries in the regions and headquarters in determining which
actions to take, OEI, in the library plan, issued general guidance and
criteria as well as digitization and dispersal procedures that outlined
the types of materials that could be (1) digitized and included in
NEPIS or dispersed to other EPA network libraries, (2) dispersed to non-
EPA libraries, and (3) disposed of or recycled. Furthermore, the
guidance instructed libraries downsizing or eliminating their
collections to, among other things, follow all applicable government
property rules and regulations, obtain the advice of the Office of
General Counsel or Regional Counsel regarding the materials needed for
rulemaking or litigation purposes, consult EPA staff experts in
different disciplines for their views on what to retain, review journal
titles to determine if they are available online or elsewhere in the
library network, and update cataloging records. Furthermore, the
guidance discouraged the establishment of minilibraries. Table 2 shows
the actions taken by the closed libraries.
Table 2: Current Status of Materials at Closed Libraries:
Program office: Office of Environmental Information;
Library: Headquarters;
Digitized: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Check].
Program office: Regional Office;
Library: Region 5;
Digitized: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Empty].
Program office: Regional Office;
Library: Region 6;
Digitized: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Empty].
Program office: Regional Office;
Library: Region 7;
Digitized: [Check];
Dispersed to EPA or non-EPA libraries: [Empty];
Disposed: [Empty].
Program office: Office of Prevention, Pesticides, and Toxic Substances;
Library: Chemical Library;
Digitized: [B];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Check].
Source: GAO analysis of EPA data.
[A] In addition to the closed libraries, libraries in Regions 2 and 3,
and the Atmospheric Sciences Modeling Division library in Research
Triangle Park, North Carolina, also digitized materials.
[B] The OPPTS Chemical Library has developed a list of materials to be
digitized but has not yet digitized any materials because of the
moratorium on further changes to the library network, and because EPA's
digitization procedures are undergoing third-party review. While these
materials sit in boxes in the headquarters repository library and the
OPPTS Chemical Library, EPA officials told us the materials can be
identified and retrieved if a request arises.
[End of table]
In terms of digitization, the criteria in the August 2006 library plan
noted that unique EPA materials--which, according to EPA officials,
refers to materials created by or for EPA--that are not already
electronically available in NEPIS would be digitized and made available
in NEPIS. The plan indicated that these materials from libraries
closing physical access would receive first priority for digitization
and, according to EPA officials, set a digitization deadline for these
materials by January 31, 2007. With the exception of the OPPTS Chemical
Library, all of the libraries that closed digitized unique EPA
materials from their library.
At the time of our review, 15,260 titles had been digitized, and EPA
anticipates that about 51,000 unique EPA library materials from closed
and open libraries will be digitized. OARM, in Cincinnati, was
responsible for digitizing materials and dispersing the hard copy of
these materials to an EPA repository or, if applicable, an originating
library.[Footnote 13] Some officials we talked with at libraries that
have not yet digitized materials indicated that they would like to do
so in the future.
In terms of dispersal, EPA's library plan noted that a library choosing
to disperse its materials can do so to one of the EPA-designated
repositories and other libraries in the library network, or it can
transfer EPA records to EPA regional record management centers. The
plan also provided guidance on what types of materials can be dispersed
to the repository libraries--EPA materials that EPA staff do not use
frequently and that are not available electronically, out-of-print
publications, and materials that have historical significance. In
addition, materials that repository libraries do not need or that other
network libraries will not accept can be dispersed to, in order of
preference, other federal agency libraries, state libraries and state
environmental agency libraries, colleges and university libraries,
public libraries, or e-mail networks used specifically to exchange
library materials. The plan also noted that some materials can be
dispersed to the Library of Congress and program office staff.
Materials that were dispersed from the closed libraries were dispersed
to other libraries within the network as well as to non-EPA libraries,
including other federal agencies, state governments, universities, and
private companies. No open libraries dispersed their materials as part
of the reorganization effort. Table 3 shows the general location of
where a majority of the dispersed materials from the closed libraries
were sent.
Table 3: General Location of Most of the Dispersed Materials from
Closed Libraries:
Program office: Office of Environmental Information;
Library: Headquarters;
Location of dispersed materials: Other EPA network libraries.
Program office: Regional Office;
Library: Region 5;
Location of dispersed materials: Other EPA network libraries, other
federal agencies, state governments, universities, and private
companies.
Program office: Regional Office;
Library: Region 6;
Location of dispersed materials: Program office: Other EPA network
libraries, other federal agencies, state governments, universities, and
private companies[A].
Program office: Regional Office;
Library: Region 7;
Location of dispersed materials: [A].
Program office: Office of Prevention, Pesticides, and Toxic Substances;
Library: Chemical Library;
Location of dispersed materials: Other EPA network libraries.
Source: GAO analysis of EPA data.
[A] Region 6 dispersed some of its materials, and Region 7 has prepared
a list of materials that will be dispersed to EPA repositories.
However, officials in both regions told us they were unable to move
forward because of the moratorium. The materials that have not been
dispersed remain on shelves in the libraries and are not directly
accessible to walk-ins from EPA staff or the public.
[End of table]
Finally, in terms of disposal, the OEI headquarters library and the
OPPTS Chemical Library disposed of some of its materials as a part of
the reorganization.[Footnote 14] EPA's library plan noted that
materials not claimed during the dispersal process could be destroyed
if they were (1) materials that are published commercially and that are
outdated; (2) materials in poor physical condition, unless their
content is rare or the item is the last copy in the network and is not
available elsewhere electronically; and (3) microfilm of journals that
are available through online archives. OPPTS officials told us that
they had followed OEI's criteria and related procedures. In total, the
OEI headquarters library has disposed of over 800 journals and books,
and the Chemical Library has disposed of over 3,000 journals and books.
EPA Is Drafting Procedures for the Library Network, and the Network's
Final Configuration Is Unknown:
Recognizing that libraries could function more cohesively as a network,
EPA established a new interim library policy in 2007, which superseded
Chapter 12 of the Information Resources Management Policy Manual and
established uniform governance and management for the network. This
interim policy held the Assistant Administrator for Environmental
Information responsible for the management of the EPA library network,
including setting policy and supporting procedures, standards, and
guidance to ensure effective oversight. The policy also (1) made
assistant and regional administrators of network libraries responsible
for complying with agencywide library policies, procedures, standards,
and guidance and (2) reestablished the National Library Program Manager
position, which was left vacant from 2005 through 2007, when many
changes related to the reorganization occurred. This interim policy
resulted in 12 draft agencywide library procedures, including
procedures on digitizing and dispersing library materials, developing
use statistics, providing public access, providing reference and
research assistance, and developing a communication strategy. EPA
officials told us that they do not have a time frame for completing
these procedures but will complete them before the Chief Information
Officer and Assistant Administrator of OEI lifts the moratorium on
changes to the network, which was imposed in January 2007 in response
to congressional and other concerns, and extended indefinitely in
February 2007. The moratorium directed EPA staff to make no changes to
library services, including closing libraries; reducing hours of
operations, services, or resources; and dispersing and disposing of
library materials.
The future of the library network, its configuration, and its
operations are contingent on the completion of the final policies and
procedures, on EPA's response to directions accompanying its fiscal
year 2008 appropriation, and on EPA's 2008 library plan. In an
explanatory statement accompanying the fiscal year 2008 Consolidated
Appropriations Act, which provides funding for most federal agencies,
including EPA, $1 million was allocated to restore the network of EPA
libraries that were recently closed or consolidated. In addition, the
explanatory statement directed EPA to submit a plan to the Committees
on Appropriations within 90 days of enactment regarding actions it will
take to restore the network. The act was signed by the President on
December 26, 2007,[Footnote 15] and EPA had not yet submitted a plan.
Separately, EPA officials told us that they are working on developing a
Library Strategic Plan for 2008 and Beyond, which details EPA's library
services for staff and the public and a vision for the future of the
library network.
EPA Did Not Effectively Justify Its Decision to Reorganize Its Library
Network:
EPA's primary rationale for reorganizing its library network was to
generate cost savings by creating a more coordinated library network
and increasing the electronic delivery of library services. However,
EPA did not fully complete several analyses, including many that its
2004 study recommended. In addition, EPA's decision to reorganize its
library network was not based on a thorough analyses of the costs and
benefits associated with such a reorganization. Therefore, we believe
that EPA's decision to reorganize the network was not fully justified.
EPA's 2004 Business Case report was initiated because of ongoing budget
uncertainties and of changes in technology and in how users obtain
information and how commercial information resources are made
available. The report concluded that EPA's libraries provide
"substantial value" to the agency and the public, providing benefits
ranging between $2.00 and $5.70 for every $1.00 spent on the
network.[Footnote 16] These benefits are based on time saved in finding
information with the assistance of a librarian. The calculated benefit-
cost ratio varied, depending on the dollar value ascribed to time
savings and the type of service provided. The report also noted other
unquantifiable benefits, such as the higher quality of information
typically found with a librarian's assistance.
Nevertheless, in response to changing conditions, the Business Case
raised concerns about the agency's ability to continue services in its
present form.[Footnote 17] As such, the report recommended that EPA
take the following actions to help facilitate an agencywide dialog
regarding the future of the library network:
* survey EPA staff who use the libraries at each location to
characterize their needs;
* inventory information resources, including books, journal
subscriptions and licenses, databases, and other licensed information
as well as library service contracts;
* characterize and assess organizational, business, and technological
factors that either enable or constrain services and resources;
* develop models of library services that address the individual needs
of participating locations, while leveraging available resources; and:
* review the existing policy framework for information resources and
develop revisions to address the roles and responsibilities of regional
offices, centers, laboratories, and program offices in providing
information services to staff.
In addition, federal guidance states that a benefit-cost analysis
should be conducted to support decisions to initiate, renew, or expand
programs or projects, and that in conducting such an analysis, tangible
and intangible benefits and costs should be identified, assessed, and
reported.[Footnote 18] One element of a benefit-cost analysis is an
evaluation of alternatives that would consider different methods of
providing services in achieving program objectives.
After issuing the Business Case report, EPA conducted several
assessments of its library network. For example, in its Optional
Approaches report, EPA provided information to EPA regional management
about their options for supporting library services beyond fiscal year
2006. The information and options provided were based on several
assessments of the network, such as consultation visits and staff
surveys. In addition, some libraries conducted their own assessment of
services. For example, after the fiscal year 2007 budget cut was
proposed, Region 1 assessed the core library services it provided,
library use, and the possible effects of the fiscal year 2007 budget
reduction on providing core services and presented a range of options
to regional management for consideration.
EPA did not fully complete its assessments, however, before it closed
libraries and began to reorganize the network. The assessments were
incomplete for the following reasons:
* EPA did not adequately survey library users to determine their needs.
EPA administered a survey to compare and contrast the relative value of
library services across program and regional offices and ascertain the
willingness of library users to accept electronic resources and
services; however, only 14 percent of EPA staff responded to the
survey. With such a low response rate, EPA could not adequately
determine user needs. The survey also did not ask questions that would
allow the agency to adequately characterize the needs of library users
in reorganizing the library network. In addition, EPA did not attempt
to gather views from, or determine the needs of, the public, which is a
significant user of EPA libraries.[Footnote 19] Furthermore, statistics
on library use across the network, which EPA relied on, in part, to
decide whether and how to reorganize the network, were incomplete and
inconsistent.[Footnote 20] EPA is now developing procedures for keeping
complete and accurate use statistics. Such statistics would allow EPA
to make more informed decisions regarding the use of its libraries and
to determine variation in use on the basis of factors such as where the
library is located organizationally, whether it is managed under a
separate contract or in combination with related information service
functions, or where it is located physically in relation to other
publicly accessed areas.
* EPA did not conduct a complete inventory of libraries' information
resources before beginning to close them. For example, journal
subscriptions are a significant cost to the agency, and these
subscriptions are duplicated throughout the network. However, EPA did
not completely assess duplication and the potential for reducing
duplication before beginning to reorganize the network.
* EPA did not fully characterize and assess organizational, business,
and technological factors that would either enable or constrain an
optimal level of library services. For example, EPA did not review, in
advance of the library closures, leading practices in digitizing
library materials to ensure that such materials are digitized and
cataloged correctly. EPA is now undergoing a third-party review of its
current digitization standards and procedures, which will inform and
serve as a benchmark for the development of EPA's future digitization
procedures for library materials. In addition, EPA is relying more on
NEPIS to distribute EPA reports electronically, but it only began
integrating NEPIS with OLS in late summer 2007 to ensure that hard copy
reports digitized in NEPIS are also available through OLS. According to
EPA officials, electronic links were established in OLS to all 26,000
reports in NEPIS by the end of December 2007. Many of the electronic
reports in NEPIS are born digital and not available in hard copy.
* EPA did not develop and fully evaluate alternative models of library
services that described the benefits, costs, opportunities, and
challenges of each approach. In its Optional Approaches report, EPA
describes five different service options: (1) current status--where a
library chooses to make no changes to the library operation; (2)
network node approach--where a library continues to provide its core
services on-site, but purchases or sells some services from or to the
library network; (3) liaison approach--where a library greatly reduces
or eliminates its physical collection and the labor needed to maintain
it with many services purchased from the network; (4) virtual services
approach--where a library maintains no library presence on-site, but
has a mechanism through which staff can purchase services and resources
directly from the network; and (5) deferral of responsibility--where a
library ceases all affiliation with the network, forcing staff to
procure information services on their own. The report explored the
estimated costs associated with each option and recommended a mix of at
least three network nodes, three liaison locations, two virtual
services locations, and participation of at least one environmental
center. However, the alternatives were based on the report's assessment
of the regional libraries, rather than on all of the libraries in the
network, and it did not explore the benefits, along with the costs, of
the various options, including the recommended "mixed" option. Thus,
each library had to decide whether it would close without having
information on what mix of closed and open libraries would present the
most beneficial option and on where to best geographically locate
Centers of Excellence or repository libraries.
* EPA did not, in advance of the reorganization, review the existing
policy framework for library resources and develop revisions to this
framework to address the roles and responsibilities of regional
offices, centers, laboratories, and program offices in providing
information services to staff. Until April 2007, EPA relied on a
library policy established in July 1987 that, by 2007, was based on an
outdated organizational scheme--the library network under the
coordination of an office that did not exist.[Footnote 21] As we have
previously discussed, EPA developed an interim library policy in April
2007, after beginning the reorganization, and is currently developing
new library procedures stemming from the policy.
According to EPA officials, EPA decided to reorganize its libraries
without fully completing the recommended analyses because it wanted to
reduce its fiscal year 2007 funding for the OEI headquarters and
regional office libraries by $2 million.[Footnote 22] However, this
claimed savings was not substantiated by any formal EPA cost
assessment. According to EPA officials, the $2 million funding
reduction was informally estimated in 2005 with the expectation that
EPA would have been further along in its library reorganization effort
prior to fiscal year 2007. Furthermore, EPA did not comprehensively
assess library network spending in advance of the $2 million estimation
of budget cuts. According to OPPTS officials, in December 2005, they
decided to close the Chemical Library to expand accessability to
library materials through digitization and to achieve related cost
savings. Although they planned on closing the Chemical Library at a
later date, they moved to close it before the start of fiscal year 2007
because the space was to be reconfigured.[Footnote 23]
By not completing a full assessment of its library resources and not
conducting a benefit-cost analysis of various approaches to
reorganizing the network, EPA did not justify the reorganization
actions in a way that fully considered and ensured adequate support for
the mission of the library network, the continuity of services provided
to EPA staff and the public, the availability of EPA materials to a
wider audience, and the potential cost savings. In effect, EPA
attempted to achieve cost savings without (1) first determining whether
potential savings were available and (2) performing the steps that its
own study specified as necessary to ensure that the reorganization
would be cost-effective.
EPA Did Not Fully Inform or Solicit Views from the Full Range of
Stakeholders on the Reorganization but Is Now Increasing Its Outreach
Efforts:
Communicating with and soliciting views from staff and other
stakeholders are key components of successful mergers and
transformations.[Footnote 24] We have found that an organization's
transformation or merger is strengthened when it makes public
implementation goals and a timeline to build momentum and show
progress. By demonstrating progress toward these goals, the
organization builds staff support for the changes. An organization's
transformation and merger is also strengthened when the organization
establishes an agencywide communication strategy and involves staff to
obtain their ideas, which among other things, involves communicating
early and often to build trust, ensuring consistency of message, and
incorporating staff feedback into new policies and procedures.
Generally, such a strategy helps gain staff ownership for the changes
and alleviates uncertainties. Finally, transformations and mergers are
strengthened when organizations learn from and use leading practices to
build a world-class organization, such as those for library services.
However, we found that (1) EPA's August 2006 library plan did not
inform stakeholders on the final configuration for the library network
or implementation goals and a timeline; (2) EPA lacked an agencywide
communication strategy for EPA staff and outside stakeholders, and the
extent to which it involved EPA staff and stakeholders to obtain their
views was limited; and (3) EPA did not solicit views from industry
experts regarding the digitization of library materials and other
issues. However, EPA is currently reaching out to both EPA staff and
external stakeholders. EPA's communication procedures were limited or
inconsistent because EPA acted quickly to make changes in response to a
proposed fiscal year 2007 funding reduction, and because of the
decentralized nature of the library network.
EPA Did Not Adequately Inform Stakeholders:
Through its August 2006 library plan, EPA generally informed internal
and external stakeholders of its vision for the reorganized library
network, noting that EPA would be moving toward a new model of
providing library services to EPA staff and the public, and that this
new model would result in a more coordinated library network where more
services would be available online. The plan discussed the creation of
Library Centers of Excellence and also noted that as a part of the
transition to the new library services model, the headquarters, Region
5, Region 6, and Region 7 libraries would close. We found, however,
that EPA did not provide sufficient information to stakeholders on how
the final library network would be configured or the implementation
goals and timeline it would take to achieve this final configuration.
More specifically, the plan did not:
* inform readers that OPPTS would close its Chemical Library, and that
other libraries would reduce their hours of operation or make other
changes to their library services;
* provide any detail on which additional libraries would, in an effort
to align to the new library service model, change their operations or
library collections in the future; and:
* inform stakeholders of the intended outcome of the reorganization
effort, including what the final configuration of the reorganized
library network would look like, and the implementation goals and
timeline needed to achieve this final configuration.
OEI officials told us that the purpose of the plan was to provide a
framework for how new services would be provided and not for the
physical configuration of the network. OEI officials also told us that
they were unsure of what the ultimate library model will look like and
whether additional libraries would close in the future, since the
decision to close is a local decision. Without a clear picture of what
EPA intends to achieve with the library network reorganization and the
implementation goals and timeline to achieve this intended outcome, EPA
staff may not know if progress is being made, which could limit support
for the network reorganization.
EPA Lacked an Agencywide Communication Strategy, and the Extent to
Which It Involved EPA Staff and Stakeholders to Obtain Their Views Was
Limited:
Because EPA's library structure was decentralized, EPA did not have an
agencywide communication strategy to inform EPA staff of, and solicit
their views on, the changes occurring in the library network, leaving
that responsibility to each EPA library. As a result, EPA libraries
varied considerably in the information they provided to staff on
library changes. For example, EPA officials from the headquarters and
three regional office libraries that closed explicitly informed EPA
staff of when the libraries would be closed to physical access.
However, EPA officials from the OPPTS Chemical Library did not inform
its staff and users of the Chemical Library closure. Rather, these EPA
officials informed them that they would be reducing library services
and then closed the library without notice or explanation to EPA staff.
These officials acknowledge that they could have made a more thorough
effort to inform library users about the timing of the library closure.
We also found that some of the closed regional libraries informed their
staff of the changes occurring at their libraries earlier than the
closed headquarters library or other closed regional libraries, and
that some libraries communicated changes to their staff more frequently
than others. Officials from Regions 5 and 6, for example, began to
inform their respective staff of their library closures about 5 months
before their libraries closed, whereas officials from Region 7 and
headquarters informed their staff of the changes occurring at their
libraries only a few weeks prior to their closures. However, we also
found that Region 7 officials communicated changes occurring at their
library to their staff more frequently after it closed as compared with
the other closed regional and headquarters libraries.
The extent to which EPA libraries solicited views from EPA staff also
varied by library. Recognizing the decentralized nature of the library
network, EPA's Optional Approaches report suggested that regional
management speak with the unions representing their staff to determine
what their staff's library needs are, assure them that changes in the
provision of library services would support their needs, and prepare
the staff for potential future changes in accessing information
resources. However, management in only a few of the regions solicited
views from their regional staff through discussions with their unions.
According to most of the union representatives we talked with from the
libraries that closed, reduced their hours of operation, or changed the
way that they provided library services to their users, they were not
asked by management to provide their views on the changes that were
occurring at their library. At the national level, OEI officials stated
that they briefed union representatives on several occasions prior to
the reorganization, and that they also provided the union with a draft
library plan for review and comment. At the time of our review, EPA had
entered into arbitration with the union to resolve the union grievance
regarding the reorganization.[Footnote 25]
Management from only a few of the regional libraries solicited views
from their regional science council--an employee group located in each
region composed of EPA scientists and technical specialists. For
example, officials in Region 1 explained that in an effort to inform
management on how best to optimize library services, given the
reduction in the budget, management asked its regional science council
to poll its scientists, engineers, and technical staff on the library
services they most value in the region. In addition, management in
Region 5 did not ask the regional science council to provide input on
the Region 5 library closure. However, the regional science council in
this region submitted a memorandum to management expressing concerns
regarding the library closing, and potential impacts the closing would
have on the duties performed by EPA scientists and engineers.
In addition, EPA generally did not communicate with and solicit views
from external stakeholders, such as the public, before and during the
reorganization because the agency was moving quickly to make changes in
response to proposed funding cuts. Of the libraries that closed, only
the headquarters library informed the public of the changes occurring
at its library by posting a notification in the Federal
Register.[Footnote 26] The notification informed members of the public
on how they could access EPA documents held in the headquarters
repository library and or in electronic format. However, the
notification was published in the Federal Register just 10 days before
the library was slated to close and become a repository library.
Furthermore, the notification did not provide public users of the
library with an opportunity to provide comments on the changes. Rather
than publishing a Federal Register notice to inform the public of
changes or to obtain public views, some of the closed libraries
announced the closures to the public through their individual library
Web sites after the closures had already occurred. In early 2007,
however, we found that EPA's Web site did not include links to the
closed regional libraries' Web sites. As a result, members of the
public had no way of knowing that the library had closed or of knowing
how to access materials that were housed in these libraries.[Footnote
27]
EPA also did not fully communicate with and solicit views from
professional library associations while planning and implementing its
library reorganization. EPA did meet with the American Library
Association, a professional library association, on a few occasions,
but did so later in the reorganization planning process. Furthermore,
other professional library associations, such as the Association of
Research Libraries, were not consulted at all by EPA officials before
or during the library reorganization.[Footnote 28]
Without an agencywide communication strategy--which involves
communicating early and often, ensuring consistency of message, and
obtaining views from both EPA staff and external stakeholders--staff
ownership for the changes may be limited, and they may be confused
about the changes. Furthermore, EPA cannot be sure that the changes are
meeting the needs of EPA staff and external stakeholders.
EPA Did Not Solicit the Views of Experts:
When developing digitization procedures for library materials, which
were noted in the library plan, EPA did not obtain the views of federal
experts, such as the Government Printing Office and the Library of
Congress, as well as industry experts. These experts could have
provided leading practice information and guidance on digitization
processes and standards for library materials. As such, EPA cannot be
sure that it is using leading practices for library services.
Recognizing the need to communicate with and solicit the views of
staff, external stakeholders, and industry experts, EPA has recently
increased its outreach efforts. In October 2007, for example, OEI asked
local unions throughout the agency to comment on a draft of the 2008
library plan, which includes an overview of EPA's library services for
staff and the public and a vision for the future of the EPA library
network. Furthermore, since April 2007, OEI has (1) attended and
presented information at a stakeholder forum hosted by the American
Library Association at which a number of professional library
associations--including the American Association of Law Libraries,
Special Libraries Association, and Medical Library Association--were
present and (2) attended and presented information at a number of
professional library association conferences. OEI has also started
working with the Federal Library Information Center Committee, a
committee managed by the Library of Congress, to develop a board of
advisers. This board of advisers--comprising senior library staff at
various agencies across the federal sector--is to respond to EPA
administrators and librarians' questions about the future direction of
EPA libraries. Furthermore, the board of advisers is to serve as one of
several experts that EPA can use as sounding boards and informal
advisers to help guide the next stages of the library reorganization.
Separately, EPA has begun to solicit advice from library experts on
procedures EPA is developing for digitization. According to OEI
officials, they will ask American Library Association officials and
other industry experts to review the procedures before they are made
final.
EPA Lacks a Strategy to Ensure Continuity of Library Services and Does
Not Know Whether Its Actions Have Impaired Access to Environmental
Information:
EPA does not have a strategy to ensure the continuity of library
services and does not know the full effect of the reorganization on
library services. However, several changes it implemented may have
impaired access to library materials and services.
EPA Does Not Have a Strategy to Ensure the Continuity of Library
Services:
EPA does not have a strategy that ensures the continuation of services
to its staff or the public. Based on our review of key practices and
implementation steps to assist mergers and organizational
transformations, organizations that are undergoing change should seek
and monitor staff attitudes and take the appropriate follow-up actions.
While EPA's library plan describes the reorganization effort as a
"phased approach," it does not provide specific goals, timelines, or
feedback mechanisms needed to allow the agency to measure performance
and monitor user needs to ensure a successful reorganization while
maintaining quality services. The plan recognizes the need to provide
training to instruct affected staff on the new services provided, but
it does not recognize the need to obtain feedback from library users
affected by the changes to identify any concerns they may have in using
the new services. EPA has begun to provide training to some staff
affected by the reorganization. The agency has also collected staff
feedback from some of the libraries; however, such efforts have been
random and have not included all of the affected library users nor a
statistically valid sample of such users. For example, the Research
Triangle Park library solicits feedback from EPA staff on the services
provided through the service agreements--and according to EPA
officials, the responses so far have been mostly positive; however, the
Region 3 library, which also provides services through a service
agreement, does not collect such feedback. Without a systematic
approach for obtaining feedback from those affected by the
reorganization, EPA cannot know whether, or to what extent, the library
reorganization has impaired the ability of library users to access
environmental information, and if it has impaired their ability, what
corrective actions it would need to take to improve services.
To balance the continued delivery of services with merger and
transformation activities, it is essential to ensure that top
leadership drives the transformation. However, during the
reorganization, EPA did not have a national program manager for the
library network to oversee and guide the reorganization effort. After
the position became vacant in late 2005, it was not filled until May
2007. Without a national program manager for the library network, EPA
did not have an official providing an essential level of oversight and
guidance that could have ensured that libraries dispersed and disposed
of materials properly and in a consistent manner. For example, we found
that a universal list of materials available for dispersal from the
libraries that were closing was not produced; rather, libraries
announced available materials on several different occasions, and the
Regions 5 and 6 libraries began dispersing materials prior to the
library plan being finalized. In addition, libraries that were closing
were not required to develop a list of materials that were to be
dispersed or disposed of. Without a program manager in place to
consolidate lists of materials to be dispersed and disposed of, some
libraries may not have been aware of materials available that could be
used for its collection. Because EPA's library plan was unclear and
lacked specific procedures and because EPA provided very little
oversight, guidance, or control over the reorganization process, it
cannot ensure that libraries properly and consistently dispersed or
disposed of its library collection, and that library services will
continue to be provided to its staff and the public.
EPA Made Several Changes That May Have Impaired the Provision of
Materials and Services:
Several changes that EPA made to its library network may have impaired
the continued delivery of library materials and services to its staff
and the public. First, according to EPA's library plan, the agency is
moving to deliver more materials and services online. According to EPA
estimates, the combined EPA collection in 2003 included 504,000 books
and reports; 3,500 journals; 25,000 maps; and 3,600,000 information
objects on microfilm. Since the reorganization began, the number of
documents in NEPIS increased from 10,700 documents to 26,000, after the
unique EPA documents from some of the libraries were digitized and
entered into the system. EPA expects to have about 51,000 documents in
NEPIS after all hard copy reports are digitized. However, according to
EPA officials, because of copyright issues, only unique reports
produced by or for EPA will be digitized. Therefore, only about 10
percent of EPA's holdings of books and reports will be available
electronically in NEPIS. If the material is not available
electronically, EPA staff in locations where libraries have closed will
receive the material through an interlibrary loan--delaying access to
the materials from 1 day to up to 20 days. According to EPA officials,
most interlibrary loan requests are completed in less than 5 days.
Second, with more library materials and services becoming available
online, EPA will be relying more on its electronic databases, such as
NEPIS and OLS, to identify and distribute library materials. However,
EPA has only just recently begun to integrate these systems to allow
for easier identification and retrieval of materials that were
digitized or that have always been available electronically; nor has it
updated these systems to reflect the current location of materials that
have been dispersed or disposed of to ensure that staff and the public
can identify and receive library materials through them. Although
dispersal procedures in EPA's library plan state that the libraries
that are closing are responsible for updating OLS, we found that they
have not done so. According to EPA officials where libraries had
closed, the staff in the receiving libraries were responsible for
updating OLS. As a result of such confusion and lack of coordination,
for example, all Chemical Library materials still appear as being
physically located at the library through OLS, although the library has
been closed for over 1 year.
Third, EPA cannot ensure that the service agreements between libraries
that had closed and other EPA libraries will be effective. Specifically:
* Only two of the seven service agreements that EPA established were
tested in advance to ensure that the services being provided were
timely and effective. Even in these cases, EPA did not consider the
full range of requests that may be received from the locations planning
to close or reduce services. For example, the service agreement between
the Cincinnati library and EPA Region 5 was tested for only 4 weeks in
2006, just before the library was to officially close on August 28,
2006. During these weeks, the number of requests made were only 3
percent of the total research and interlibrary loan requests made in
Region 5 during fiscal year 2006. This does not provide a realistic
assessment of the Cincinnati library's ability to fulfill research
requests and interlibrary loans in a timely and effective fashion. Even
for this 3 percent, EPA surveyed only a sample of staff to determine
their satisfaction with the library services.
* Library materials and services provided under the service agreements
are based on a fee-for-service arrangement, which could constrain
access to information. For example, due to reduced budgets, prior to
the reorganization, OPPTS required management approval of research
requests and other service requests. If the agency finds that costs are
more than anticipated under the new fee-for-service model, it may
require such approvals to try to limit costs. Such actions could limit
the research that EPA staff conduct and also delay research efforts.
EPA officials have stated that they believe the service agreements
provide adequate services and, thus far, believe that they are cost-
effective based on preliminary results.
* The Centers of Excellence libraries that provide services to the
locations that closed their libraries are all based in the Eastern time
zone, which may constrain when services can be provided, especially for
EPA staff located in the West.
Although EPA is attempting to continue to meet the needs of its staff,
it does not have a plan in place to ensure the continuation of library
services for the public, such as state and local government
environmental agencies, environmental groups, and other nongovernmental
organizations. EPA's library plan stated that the locations where
libraries have closed would have a plan to manage public inquiries, and
that such locations would refer public requests for information to the
public affairs office or program staff. However, we found that many of
the locations where libraries closed have not developed such a plan. In
addition, the service agreements with the locations where libraries
closed only refer to how services would be provided to EPA staff and
not the public.
Finally, EPA may have inadvertently limited access to information
because it did not determine whether federal property management
regulations applied to the dispersal and disposal of library materials
and hence may have disposed of materials that should have been
retained. To ensure that federal property is reused to the extent
possible, regulations generally require that agencies report surplus
property to GSA, which will attempt to find another agency that needs
it. If no federal agency needs the property, it may be sold to the
public or donated to state or local governments or nonprofit entities.
Although agencies may discard property that is subject to the
regulations, they must first make a written determination that the
property has no value.
While EPA's Fiscal Year 2007 Library Plan included dispersal and
disposal criteria and procedures for libraries to follow when deciding
on its collections, these criteria and procedures were vague and did
not incorporate the federal property regulations. According to a Region
3 EPA official who developed the dispersal and disposal criteria, a
clear answer from GSA and from EPA property management officials was
not obtained regarding the applicability of federal property management
regulations to library materials in the time available before the plan
was issued. Furthermore, many of the individual libraries that had
dispersed or disposed of library materials did not contact GSA, EPA
property management officials, or EPA legal counsel to determine
whether federal property management regulations applied, and did not
consider the applicability of the federal property management
regulations before dispersing or disposing of their library materials.
As a result, EPA libraries dispersed and disposed of library materials
in a manner inconsistent with federal property management regulations.
For example, the Regions 5 and 6 libraries gave materials to private
companies, and the OEI headquarters library and the Chemical Library
discarded materials without first determining that they had no monetary
value. Furthermore, several journal titles from the Chemical Library
were disposed of, despite the fact that EPA's Office of Enforcement and
Compliance Assurance offered to take the materials and archive them.
EPA officials stated that there was lack of clarity regarding whether
library materials, such as books and journals, were subject to federal
property management regulations. EPA officials stated that they will
look into this matter more and will engage federal property management
officials at GSA regarding what steps should be taken.
EPA Program Offices Are Responsible for Funding Their Libraries and
Their Reorganization Through Their Support Budgets:
The several different program offices responsible for the EPA libraries
in the network generally decide how much of their available funding to
allocate to their libraries out of larger accounts that support
multiple activities. There is no line item for EPA libraries included
in the President's budget nor in EPA's more detailed budget
justification to Congress. Until fiscal year 2007, library spending had
remained relatively stable, ranging from about $7.14 million to $7.85
million between fiscal years 2002 and 2006.[Footnote 29] OEI, which is
the primary source of funding for the regional libraries, typically
provides funding for them through each region's support budget, and
generally gives regional management discretion on how to allocate this
funding among the library and other support services, such as
information technology. The regions also obtain a much smaller portion
of their library funding from other program offices, such as Superfund,
to store and maintain information on the National Priorities List.
[Footnote 30] The extent to which other program offices provide funding
to the regional libraries varies.
For the OEI headquarters library and the regional office libraries,
however, the approach to library support changed in fiscal year 2007.
OEI management decided to reduce library funding by $2 million from
$2.6 million in enacted funding in fiscal year 2006 for the OEI
headquarters and regional office libraries--a 77 percent reduction for
these libraries and a 28 percent reduction in total library funding.
After $500,000 of the $2 million reduction was applied to the
headquarters library, the regional administrators together decided that
the remaining $1.5 million reduction should be spread equally across
all regions, rather than by staffing ratios in each region or previous
years' spending. However, because it was one of the agencies included
in the full-year continuing appropriations resolution for fiscal year
2007, EPA operated near fiscal year 2006 funding levels. According to
EPA, OEI restored $500,000 to the library budget in fiscal year 2007 to
support reorganization activities. According to OPPTS officials, while
OPPTS did not face a budget cut for fiscal year 2007, it decided to
close its Chemical Library nevertheless to improve the library's online
services and achieve cost savings.
For EPA staff who had used the libraries that are now closed, EPA has
established service agreements with Centers of Excellence. These
libraries provide materials and services on a fee-for-service basis
charged to the program office whose staff made the request. Funding is
provided either as a lump sum to these libraries at the beginning of
the fiscal year, which is drawn from as needed, or funding is provided
on a monthly basis. The libraries provide monthly reports to the
locations being served and coordinate with a liaison at these
locations. EPA estimates that services provided under these agreements
will cost approximately $170,000 for fiscal years 2007 and 2008.
When planning for the reorganization of the library network, EPA
recognized that the responsible dispersal, disposal, and digitization
of an EPA library collection is a major project requiring planning,
time, and resources. For example, when the relatively small library in
Edison, New Jersey, closed in 2004, EPA estimated that it cost $150,000
to disperse 1,000 boxes of materials. EPA did not allocate funds
specifically to help the closing libraries manage their collections.
According to EPA, the funding for library closures was taken into
account during the budget process. As a result, the program or regional
office responsible for the library used its usual library funding to
pay for closing costs.
The program offices that closed their libraries did not track closing
costs, such as boxing and shipping materials. However, EPA estimated
that it cost approximately $80,000 to digitize 15,260 titles between
December 2006 and January 2007. This cost was paid for by OARM under an
already existing contract.
Conclusions:
EPA recognized it needed to ensure that, during and following the
reorganization, its library network would continue to provide
environmental information to EPA staff and external stakeholders.
Accordingly, the agency's reorganization planning identified procedures
to follow that would enable the libraries to continue the availability,
quality, and timeliness of library materials and services. However,
because of a proposed reduction in funding for the OEI headquarters and
regional office libraries in fiscal year 2007, EPA did not fully
implement these procedures, instead it acted quickly to make changes.
In addition, EPA did not rigorously conduct outreach efforts with EPA
staff, external stakeholders, and outside experts, which we have
recognized as steps necessary for a successful merger or
transformation. As a result, support for the library reorganization may
be limited, and staff may be confused about the changes. Furthermore,
EPA cannot be sure that the changes are meeting the needs of EPA staff
and external stakeholders, and that it is incorporating leading
practices for library services and the digitization of materials.
Finally, EPA did not implement best practices that would allow it to
measure or monitor the effects of the reorganization or provide
oversight of the process, despite EPA having made changes to its
library network that may have negatively affected how materials and
services are provided to its staff and the public. For example, EPA did
not disperse and dispose of library materials in accordance with
federal property management regulations or its own procedures and,
therefore, may have disposed of materials that are of value and needed
for use by staff and the public. Without sufficient monitoring or
oversight of the process, EPA cannot be sure of the extent to which the
library reorganization has degraded library services, if at all, and
therefore cannot take corrective actions if necessary.
Recommendations for Executive Action:
To ensure that critical library services are provided to EPA staff and
other users, we recommend that the Administrator of EPA continue the
agency's moratorium on changes to the library network until the agency
incorporates and makes public a plan that includes the following four
actions:
* Develop a strategy to justify its reorganization plans by (1)
evaluating and determining user needs for library services; (2) taking
an inventory of EPA information resources and determining the extent to
which these resources are used; (3) evaluating technological factors,
such as digitization procedures and integration of online databases, to
ensure an optimal level of services; (4) evaluating and conducting a
benefit-cost assessment for each alternative approach for the network,
including the approach that existed before the reorganization; and (5)
reviewing and revising, as appropriate, the existing policy and
procedures that guide the library network.
* Improve its outreach efforts by developing a process that (1) informs
stakeholders of the final configuration of the library network, and the
implementation goals and timeline to achieve this configuration; (2)
communicates information to stakeholders early, often, and consistently
across all libraries, and solicits the views of EPA staff and external
stakeholders; and (3) obtains the views of industry experts to
determine leading practices for library services.
* Include a process that (1) ensures sufficient oversight and control
over the reorganization process, (2) continuously and consistently
monitors the impact of the reorganization on EPA staff and the public,
and (3) takes corrective actions as necessary to provide the continued
delivery of services.
* Implement procedures that ensure that library materials are dispersed
and disposed of consistently and in accordance with federal property
management regulations.
Agency Comments:
We provided EPA with a draft of this report for its review and comment.
In its written response, EPA agreed with our recommendations, stating
that it will prioritize the recommendations when moving forward on
modernizing the library network. EPA also provided comments to improve
the draft report's technical accuracy, which we have incorporated as
appropriate. EPA's letter is reprinted in appendix III.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to interested congressional committees, the Administrator of EPA, and
other interested parties. We will also make copies available to others
upon request. In addition, this report will be available at no charge
on the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or stephensonj@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major contributions
to this report are listed in appendix IV.
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
List of Requesters:
The Honorable John D. Dingell:
Chairman:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Bart Gordon:
Chairman:
Committee on Science and Technology:
House of Representatives:
The Honorable Henry Waxman:
Chairman:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Barbara Boxer:
Chairman:
Committee on Environment and Public Works:
United States Senate:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
To review the Environmental Protection Agency's (EPA) library network
reorganization, we (1) determined the status of, and plans for, the
library network reorganization; (2) evaluated EPA's rationale for its
decision to reorganize the library network; (3) assessed the extent to
which EPA communicated with and solicited views from EPA staff and
external stakeholders in planning and implementing the reorganization;
(4) evaluated the steps EPA has taken to maintain the quality of
library services following the reorganization, both currently and in
the future; and (5) determined how EPA is funding the library network
and its reorganization.
We limited our review to the 26 libraries that were part of the EPA
library network. According to EPA officials, a library is considered
part of the network if its collections are listed in the agency's
Online Library System (OLS). Generally, we also conducted the following
activities:
* Reviewed relevant EPA documents, plans, policies, guidance, and
procedures as well as related laws and requirements pertinent to the
library network and the reorganization effort.
* Visited the Office of Environmental Information's (OEI) headquarters
library and the Office of Prevention, Pesticides, and Toxic Substances'
Chemical Library--both located in Washington, D.C.; the Region 10
library in Seattle, Washington; and the Office of Administration and
Resources Management (OARM) library in Cincinnati, Ohio. We visited
these libraries because the headquarters library closed physical access
to its library space and transitioned into a repository library; the
Chemical Library closed physical access to its library space and
dispersed and disposed of its library materials; the Region 10 library
reduced its hours of operation; and the OARM library in Cincinnati was
identified by EPA as a repository library, a Center of Excellence, and
the facility was responsible for digitizing library materials from the
closed EPA libraries.
* Interviewed representatives from Lockheed Martin and Integrated
Solutions and Services--because these two companies digitized and
electronically indexed library materials through already existing
contracts with OARM in Cincinnati--and visited a Lockheed Martin
facility to observe the digitization process.
* Interviewed EPA librarians, library managers, and program office and
regional office managers for the 26 libraries in EPA's library network.
When possible, we corroborated information provided to us by EPA
officials during the interviews with relevant documentation.
For each of our objectives, some analysis was based on documentation
and information provided to us by EPA officials. To the extent
possible, we tried to corroborate this information. However, we did not
independently verify this information or assess whether it was complete
or accurate.
In addition, we conducted work that was specific to each of the
report's objectives. To determine the status of and plans for the
library network reorganization, we analyzed information that EPA
libraries provided to us on the operating status of the libraries as
well as materials that have been digitized, dispersed to other EPA and
non-EPA libraries, or disposed of as a part of the reorganization
effort. We also reviewed drafts and final versions of EPA procedures
and criteria for digitizing, dispersing, and disposing of EPA library
materials.
To evaluate EPA's rationale for reorganizing the library network, we
conducted the following activities:
* Reviewed documents that EPA developed before the reorganization in
fiscal year 2007. One of these documents was EPA's 2004 study on the
costs and value of EPA's libraries.[Footnote 31] We did not assess the
robustness and adequacy of the methodology and data that EPA used for
this study. However, we used this study's recommendations for
information on how to further assess and determine the future of the
library network to guide our assessment of EPA's subsequent evaluation
efforts of the library network. We spoke with a contract official from
Stratus Consulting, which helped develop the 2004 study on the costs
and value of EPA's libraries, as well as with a researcher from Simmons
College who helped conduct an independent review of the study. In
addition, we reviewed federal guidelines from the Office of Management
and Budget on benefit-cost analyses. We also assessed EPA's survey of
library users, examining the adequacy of the response rate of the
survey and survey questions. We found the 14 percent response rate to
EPA's survey not to be adequate for EPA's purpose because the response
rate was low and because EPA did not do any nonresponse analyses to
show that those 14 percent who responded were representative of the
target population. To determine whether EPA's survey contained
questions to adequately characterize the needs of library users in
reorganizing the library network, we looked for survey questions that
assessed how and how often users used the library space, the library
holdings, and the librarian in performing their jobs; the utility of,
and satisfaction with, each resource; and to what extent the library
materials were available electronically versus in hard copy.
* Asked each of the 26 libraries to provide us with data on the number
of walk-ins to the library and other use data between fiscal years 2000
and 2006. We reviewed these data to determine their reliability and
sufficiency for EPA to use as a basis for deciding to reorganize the
library network. To determine the reliability and sufficiency of EPA's
library use data, we checked whether all libraries kept such statistics
and whether enough years of data were available to detect a trend in
the level of use. We found that not all libraries tracked such library
use data and some libraries only kept data for a limited number of
years.
* Assessed the National Environmental Publications Internet Site
(NEPIS) and OLS to determine the extent of integration between the two
systems and to determine how the location of library materials that
have been dispersed or disposed of are being updated in OLS.
* Assessed the comprehensiveness of EPA's efforts to evaluate
alternative models of library services.
To assess EPA's efforts to communicate with and solicit the views of
EPA staff and external stakeholders in planning and implementing the
reorganization, we reviewed our past work on key practices and
implementation steps to assist mergers and organizational
transformations and compared these key practices and implementation
steps with EPA's reorganization effort (app. II provides more details
on these key practices and implementation steps). More specifically, to
determine EPA's efforts to communicate with and solicit input from
stakeholders, we reviewed e-mails, notices, and memorandums from EPA
library management and program office and regional office management to
EPA staff. We also interviewed local union representatives from
headquarters and all of EPA's regional offices. Furthermore, we
interviewed regional science council representatives from most of the
regional offices. The science councils are located in each regional
office and consist of EPA scientists and technical specialists. To
determine the extent to which EPA communicated with and solicited views
from outside stakeholders, we interviewed representatives from several
professional library associations and other external stakeholder
groups, such as the American Library Association, the Association of
Research Libraries, the American Association of Law Libraries, the
Special Libraries Association, the Library of Congress' Federal Library
and Information Center Committee, and the Union of Concerned
Scientists. We also reviewed information that EPA provided to the
public via the EPA Web site or, when applicable, Federal Register
notices.
In evaluating the steps that EPA has taken to maintain the quality of
library services following the reorganization both currently and in the
future, we reviewed our past work on key practices and implementation
steps to assist mergers and organizational transformations and compared
these key practices and implementation steps with EPA's reorganization
effort (app. II provides more details on these key practices and
implementation steps). Furthermore, we reviewed federal property
management regulations regarding the dispersal and disposal of federal
property, and assessed whether EPA followed these regulations. We also
reviewed drafts and final versions of EPA procedures and criteria for
dispersing and disposing of EPA library materials. Separately, we
determined the possible effects of changes to the library network by
(1) determining and evaluating the total number of library materials
that would be digitized and made available in NEPIS, and the length of
time it would take a user to receive materials via interlibrary loan;
(2) evaluating the accuracy of information in NEPIS and OLS; and (3)
reviewing and evaluating service agreements between libraries. Finally,
we reviewed the roles and responsibilities of the EPA library network
management.
To determine funding for the library network and its reorganization, we
obtained information on library funding from each of the 26 libraries
in the network between fiscal years 2002 and 2007. Because EPA does not
specifically track funding for the libraries, the information provided
contained a mix of outlays for some fiscal years and budget authority
for other fiscal years. In addition, the information provided from each
of the libraries only reflected spending by the library and not the
source of the funds. For example, a large portion of the funding for
the regional office libraries come from OEI, but funding is also
received from other EPA program offices, such as Superfund.
Furthermore, the funding data received from the libraries contained a
mix of funding for contract support; library staff salaries; and
acquisition costs for books, journals, and other materials. We
interviewed EPA officials to assess data reliability, but we did not
independently verify the accuracy and completeness of the data that
they provided. After discussions with EPA officials, we decided not to
include a table showing funding for each library for fiscal years 2002
through 2007 because of concerns with its reliability. Separately, we
interviewed library management from each of the 26 libraries to obtain
information on the costs of the reorganization.
We conducted this performance audit from December 2006 through February
2008 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Key Practices and Implementation Steps for Effective
Mergers and Organizational Transformations:
Practice: Ensure top leadership drives the transformation;
Implementation step:
* Define and articulate a succinct and compelling reason for change;
* Balance continued delivery of services with merger and transformation
activities.
Practice: Establish a coherent mission and integrated strategic goals
to guide the transformation;
Implementation step:
* Adopt leading practices for results-oriented strategic planning and
reporting.
Practice: Focus on a key set of principles and priorities at the outset
of the transformation;
Implementation step:
* Embed core values in every aspect of the organization to reinforce
the new culture.
Practice: Set implementation goals and a timeline to build momentum and
show progress from day one;
Implementation step:
* Make public implementation goals and timeline;
* Seek and monitor employee attitudes and take the appropriate follow-
up actions;
* Identify cultural features of merging organizations to increase
understanding of former work environments;
* Attract and retain key talent;
* Establish an organizationwide knowledge and skills inventory to
exchange knowledge among merging organizations.
Practice: Dedicate an implementation team to manage the transformation
process;
Implementation step:
* Establish networks to support implementation team;
* Select high-performing team members.
Practice: Use the performance management system to define
responsibility and ensure accountability for change;
Implementation step:
* Adopt leading practices to implement effective performance management
systems with adequate safeguards.
Practice: Establish a communication strategy to create shared
expectations and report related progress;
Implementation step:
* Communicate early and often to build trust;
* Ensure consistency of message;
* Encourage two-way communication;
* Provide information to meet specific needs of employees.
Practice: Involve employees to obtain their ideas and gain their
ownership for the transformation;
Implementation step:
* Use employee teams;
* Involve employees in the planning and sharing of performance
information;
* Incorporate employee feedback into new policies and procedures;
* Delegate authority to the appropriate organizational levels.
Practice: Build a word-class organization;
Implementation step:
* Adopt leading practices to build a world-class organization.
Source: GAO.
[End of table]
[End of section]
Appendix III: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Office of Environmental Information:
Washington, D.C. 20460:
Internet Address (URL): [hyperlink, http://www.epa.gov]:
February 14, 2008:
Mr. John B. Stephenson
Director:
Natural Resources and Environment:
United States Government Accountability Office:
Washington, DC 20548:
Re: EPA Comments on the Government Accountability Office's (GAO) draft
report to Congress entitled EPA Needs to Ensure That Best Practices and
Procedures Are Followed When Making Further Changes to its Library
Network (GAO-08-304):
Dear Mr. Stephenson:
This letter provides the U.S. Environmental Protection Agency's (EPA)
comments on GAO's draft report entitled EPA Needs to Ensure That Best
Practices and Procedures Are Followed When Making Further Changes to
its Library Network (GAO-08-304). EPA appreciates the thorough and
thoughtful review GAO conducted as well as the opportunity to provide
comments on this draft report to Congress.
EPA understands the importance of access to its environmental
information and is fully committed to enhancing the EPA National
Library Network (Network) to make library information available to a
wider audience. The Network model that existed before our efforts began
was outdated, having been in existence for more than 30 years. EPA
libraries have adopted new technologies over time to support their
functions, but much more needed to be done to become a true 21st
century operation and a leader among government libraries.
The move to increased electronic delivery of information, the
information delivery needs of a customer base working from a myriad of
locations, and the growing demands for information and data prompted
EPA to re-evaluate its longstanding operational models and move the
Network into a new phase that can address current and future needs.
These trends have emphasized the need for EPA to identify different
ways to operate its libraries while continuing to serve an ever-growing
and demanding customer base in a cost-effective manner.
GAO's draft report raises concerns about the process EPA used in making
changes to its Network. EPA believes it relied on several previous
studies of its Network to inform its decisions. These studies examined
a wide range of options and issues, and were supplemented with
information on local needs for changes specific to individual
libraries. EPA ran a cross-Agency process to carefully consider this
information and to obtain input from Agency managers and staff When
implementing changes, EPA staff worked hard to follow best library
practices and to meet applicable federal requirements.
We do understand the need to be transparent in our planning around
library services. EPA has already taken steps which mirror a number of
the GAO recommendations in the draft report. Some of those steps
include:
Increased Communication and Outreach:
During the past year EPA increased its communication with internal and
external stakeholders. EPA has participated in several meetings with
professional library associations, including the American Library
Association (ALA), Special Libraries Association (SLA), American
Association of Law Libraries (AALL), as well as the Union of Concerned
Scientists in an effort to get input and share information on Network
operations, delivery of services, and plans for the future. EPA will
continue these efforts as we develop the strategic direction of the
Network.
EPA is also working with the Federal Library and Information Center
Committee (FLICC) on EPA plans for the future delivery of library and
information access services. FLICC provides advice to federal libraries
and information centers in all branches of government, and its mission
is to foster excellence in federal library and information services
through interagency cooperation. FLICC has identified a board of
advisors to work with EPA staff to help address challenges and share
collective expertise and experience. The board, whose membership
includes representatives from a number of federal libraries, is working
with EPA to advise on strategic direction and procedures being
developed to support operations within the Network.
We have also provided additional information online about our
libraries. In order to provide up-to-date information for people
seeking information from EPA libraries, we have updated all Network
library web pages to have a consistent design and to provide contact
information [hyperlink, http://www.epa.gov/libraries/index.html]. We
are using these web pages as a mechanism to solicit feedback on current
library services and the future direction of the Network. For example,
EPA posted information on digitization procedures [hyperlink,
(http://www.epa.gov/nscep/DigitizationReport.pdf#zoom--100] in an
effort to gather feedback.
Enhanced Policy and Procedures:
An interim policy for the EPA National Library Network Policy was
issued in April 2007, which assigned responsibility for the Network to
EPA's Assistant Administrator of the Office of Environmental
Information, and established uniform governance and management for the
Network. The policy applies to all EPA headquarters and regional
offices that provide library services. The final policy will include a
number of standard procedures that will be mandatory for all Network
libraries. EPA is sharing these procedures with external stakeholders.
These Network-wide procedures complement local library procedures that
have been in place for a number of years.
Sound Planning for a Strong and Effective Network:
EPA is developing a Strategic Plan for the EPA National Library Network
and will continue to solicit input from its stakeholders, both internal
and external. EPA plans to conduct a needs assessment to inform the
strategic planning process. The resulting plan will set overall
goals and objectives and a direction for implementation of library
services for EPA staff and the public. The plan will recognize the
differences in function, the audiences served, and the scope of
collections of the libraries in the Network.
Enhance the Network of EPA Libraries:
In accordance with report language on the Consolidated Appropriations
Act of 2008, EPA is working to ensure on-site support to libraries in
EPA Regions 5, 6, and 7, as well as to the Office of Pollution,
Prevention, and Toxic Substances (OPPTS) Chemical Library and the
Headquarters Library. All these libraries will provide access and
services for EPA staff and the public, onsite trained library staff,
and a collection of core library materials.
EPA appreciates all the recommendations set forth in the GAO draft
report. As we move forward with the modernization of our entire library
network, the Agency will prioritize the recommendations made by this
draft report.
Let me reassure you that EPA understands the importance of access to
its environmental information, values the EPA National Library Network,
and recognizes the crucial role it plays in accomplishing the Agency's
mission. In addition to these general comments, I have also enclosed a
set of specific technical comments. If you would like to discuss these
matters further, please contact me at 202-564-6665, or your staff may
contact Emma McNamara, Director of the Information Access Division, at
202-566-0655.
Sincerely,
Signed by:
Molly A. O'Neill:
Assistant Administrator and Chief Information Officer:
Enclosure:
cc: OCIR:
OCFO:
OPPTS:
ARAs:
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
John Stephenson, (202) 512-3841 or stephensonj@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Ed Kratzer, Assistant Director;
Nathan A. Morris; Roshni Davé; and Carol Herrnstadt Shulman made key
contributions to this report. Also contributing to this report were
Mike Dolak, Carol Henn, Kunal Malhotra, Bonnie Mueller, Lynn Musser,
Omari Norman, Kim Raheb, Sarah Veale, and Greg Wilmoth.
[End of section]
Footnotes:
[1] At one point, the network included up to 28 libraries.
[2] There is no line item for EPA libraries included in the President's
budget proposal, nor is such a line item in EPA's more detailed budget
justification to Congress. The $2 million budget reduction for the OEI
headquarters library and the regional office libraries was identified
in EPA's fiscal year 2007 straw budget, issued on July 8, 2005, out of
a total reduction of $10 million for information technology data
management under OEI. The Office of Administration and Resources
Management also received a reduction in fiscal year 2007 of $1 million
for scientific journal subscriptions, but $473,000 of the total was
redirected to the Office of Research and Development to continue these
journal subscriptions.
[3] A Center of Excellence is another library in the network that
provides specific library services to a program office on the basis of
its needs. EPA initially referred to these libraries as Centers of
Expertise in the 2006 library plan.
[4] Two other repository libraries are managed by the Office of
Administration and Resources Management in Research Triangle Park,
North Carolina, and Cincinnati, Ohio.
[5] GAO, Results-Oriented Cultures: Implementing Steps to Assist
Mergers and Organizational Transformations, GAO-03-669 (Washington,
D.C.: July 2, 2003).
[6] GAO-03-669.
[7] There are also several libraries and entities at EPA that are not
considered part of the network. They include small law libraries
located in many of the regions, and entities that are considered
resource centers, such as the Water Resources Center. According to EPA
officials, these libraries or entities are not part of the network
because their holdings are not cataloged in EPA's Online Library
System.
[8] OEI primarily funds these regional office libraries.
[9] U.S. Environmental Protection Agency, Office of Environmental
Information, Business Case for Information Services: EPA's Regional
Libraries and Centers, EPA 260-R-04-001 (January 2004); and Optional
Approaches to U.S. EPA Regional Library Support, EPA 260-R-05-002 (June
2005).
[10] On September 25, 2007, a ruling by a Federal Labor Relations
Authority administrative law judge found that EPA violated federal
labor law by failing to enter arbitration with the union regarding the
grievance. U.S. Environmental Protection Agency v. American Federation
of Government Employees, Council 238, No. CH-CA-07-0425 (Sept. 25,
2007). On February 15, 2008, an arbitrator found that EPA had violated
provisions of the Master Collective Bargaining Agreement by not
engaging the union in impact and implementation bargaining pertaining
to the reorganization of its library network. EPA v. American
Federation of Government Employees Council 238, FMCS Case No. 07-50725
(George Edward Larney, Arbitrator).
[11] These libraries have been designated to be Centers of Excellence
for the EPA library network, meaning that these libraries have staff
qualified to conduct research in specific areas, have access to tools
to support services, and have the ability to handle increased workload.
According to EPA officials, the OARM libraries serve as Centers of
Excellence for core library services, such as research requests and
interlibrary loans, and the Region 3 library serves as a Center of
Excellence for business research issues.
[12] In addition, a service agreement was established between the
Research Triangle Park library and the National Center for
Environmental Assessment in Washington, D.C.
[13] OARM officials in Cincinnati stated that this digitization work
was performed by Lockheed Martin, under an already existing contract,
and by Integrated Solutions and Services.
[14] Region 5 officials told us that some journal titles were disposed
of, but that these materials were disposed of through normal library
"weeding" procedures. Weeding is part of a library's regular collection
maintenance program, whereby worn, rarely used, or no longer needed
titles are identified and disposed of. According to Region 5 officials,
they did not keep a list of the journal titles that were disposed of
through this process. In addition, officials from the National Vehicle
and Fuel Emissions Laboratory Library noted that they obtained
permission from OEI to dispose of about 100 materials that were damaged
during a flood in 2007. According to these officials, most of these
materials were not used often and are available electronically. This
library did maintain a list of the titles that were disposed of.
[15] Pub. L. No. 110-161.
[16] This study only focused on the OEI headquarters library, the 10
regional office libraries, and the OARM libraries located in Cincinnati
and Research Triangle Park.
[17] Before the Business Case report was finalized, EPA conducted an
independent, third-party review of the report. According to the third-
party review, the benefit-cost assessment was methodologically sound.
However, it found that the report was rooted on a current "as-is,"
nonstrategic setting and did not provide an empirical, fact-based basis
on what might be alternative library service configurations for
creating greater value to EPA. As such, the Business Case report was
found not to address critical questions, such as opportunities for
improvements through the centralization of services, changing staffing
patterns, or closer alignment with the mission and goals of the agency.
According to the third-party review, the Business Case report only
suggested that the network could be run more efficiently without giving
a valid justification as to why or how. In moving forward, the third-
party review (1) suggested that, in the long term, EPA should examine
ways in which the EPA library services and network can be more closely
supported by, and aligned with, the agency's strategic goals and (2)
made some specific recommendations on what EPA could do in the short
term to more fully evaluate the network and determine alternative
models of service.
[18] Office of Management and Budget, Guidelines and Discount Rates for
Benefit-Cost Analysis of Federal Programs, OMB Circular A-94
(Washington, D.C.: Oct. 29, 1992).
[19] According to EPA estimates, 20 to 40 percent of the reference
requests received by regional libraries are from the public.
[20] EPA has reported that a significant drop in walk-ins to the
libraries was a major factor in deciding to reorganize the library
network and establish a more virtual approach to providing library
materials and services. However, a review of walk-in statistics and
other use statistics reveals that some libraries did not keep complete
statistics. For example, Regions 4 and 6 did not keep statistics on the
number of walk-ins, and several other libraries did not keep these
statistics prior to 2003. For the regional libraries that did keep
track of the number of walk-ins, these statistics showed that walk-ins
had decreased only 18 percent from 2003 through 2006; ranging from a
decrease of 83 percent in Region 5 to an increase of 66 percent in
Region 10.
[21] The position of national program manager for the EPA library
network was located within the Information Services Branch of the
Information Management and Services Division, Office of Information
Resources Management--a predecessor to OEI.
[22] The $2 million cost savings for the libraries was included in the
President's fiscal year 2007 budget proposal for EPA. However, like
most agencies, EPA was included in the full-year continuing resolution,
which held appropriations near fiscal year 2006 levels.
[23] Nearly half of the space in the Chemical Library is occupied by
shelving units. Because the space and the shelving are considered to be
historical, EPA cannot remove the shelves. The rest of the space has
been converted to cubicles.
[24] See GAO-03-669. This report identified nine key practices and
related implementation steps that have led to successful mergers and
transformations in large private and public sector organizations. Since
all nine key practices and implementation steps could help guide EPA's
library reorganization effort, we have included this information in
appendix II.
[25] In September 2007, the national EPA union held arbitration talks
with EPA. The EPA union won its unfair labor practice claim against the
agency. More specifically, the Federal Labor Relations Authority
administrative law judge ruled that EPA violated federal labor law by
failing to enter arbitration with the union regarding its grievance
about the library restructuring. U.S. Environmental Protection Agency
v. American Federation of Government Employees. The ruling also
required the agency to post signs notifying employees that EPA had
violated labor law. On February 15, 2008, an arbitrator found that EPA
had violated provisions of the Master Collective Bargaining Agreement
by not engaging the union in impact and implementation bargaining
pertaining to the reorganization of its library network. EPA v.
American Federation of Government Employees Council 238, FMCS Case No.
07-50725 (George Edward Larney, Arbitrator).
[26] 71 Fed. Reg. 54,986 (Sept. 20, 2006).
[27] EPA has since revised its Web site to include links to the closed
EPA libraries. The individual library Web sites for the closed
libraries direct library users to EPA online resources, such as OLS and
NEPIS, or to the library with which they have established a service
agreement.
[28] The Association of Research Libraries has developed a library
assessment tool--called LibQUAL+--that allows libraries to measure and
report on library service quality.
[29] These figures are based on estimates from EPA. We did not
independently determine their accuracy. Because EPA does not track
library funding, each library in the network provided estimates that
were based on past spending and enacted funding. However, libraries may
have varied in the type of spending data provided in terms of whether
the data included contract costs, salaries, and acquisitions.
[30] The National Priorities List is EPA's list of the most dangerous
hazardous waste sites in the country.
[31] U.S. Environmental Protection Agency, Office of Environmental
Information, Business Case for Information Services: EPA's Regional
Libraries and Centers, EPA 260-R-04-001 (January 2004).
[End of section]
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