Environmental Protection
EPA Needs to Follow Best Practices and Procedures When Reorganizing Its Library Network Gao ID: GAO-08-579T March 13, 2008Established in 1971, the Environmental Protection Agency's (EPA) library network provides access to critical environmental information that the agency needs to fulfill its mission of protecting human health and the environment. The library network also provides information and services to the public. In fiscal year 2006, the network included 26 libraries across headquarters, regional offices, research centers, and laboratories. These libraries were independently operated by several different EPA program offices, depending on the nature of the libraries' collections. In 2006, facing proposed budget cuts, EPA issued a plan to reorganize the network beginning in fiscal year 2007. The plan proposed a phased approach to closing libraries and dispersing, disposing of, and digitizing library materials. GAO was asked to summarize the findings in its report being released today, 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 made four recommendations in this report aimed at best practices and procedures that EPA should follow when continuing to reorganize its library network. The agency agreed with the recommendations.
Since 2006, EPA has implemented its library reorganization plan and has closed physical access to the Office of Environmental Information (OEI) headquarters library and three regional office libraries. In the same period, six other libraries in the network independently changed their operations. Some of these libraries digitized, dispersed, or disposed of their materials before EPA had drafted a common set of agencywide library procedures for doing so. Until these procedures are completed, EPA plans no further changes to the library network. EPA reorganized its library network primarily to generate cost savings through a more coordinated library network and more electronic delivery of services. However, GAO found that EPA did not effectively justify its reorganization decision. According to EPA officials, OEI decided to reorganize its libraries without fully completing the recommended analyses in order to reduce its fiscal year 2007 funding in response to the President's fiscal year 2007 budget proposal. EPA did not systematically inform the full range of stakeholders on the final configuration of the library network. In addition, 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 effort. EPA is currently reaching out to stakeholders, including EPA staff and library experts, by holding and attending stakeholder meetings and conferences. EPA does not yet 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. 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. EPA did not follow 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. The several different program offices responsible for the EPA libraries in the network each generally decide how much of their available funding to allocate to their libraries and how to fund their reorganization. However, when faced with a proposed budget reduction of $2 million in fiscal year 2007, rather than following its normal procedures, OEI 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 allocate funds to help closing libraries manage their collections; instead, the responsible program or regional office used its annual funding to pay for these costs.
GAO-08-579T, Environmental Protection: EPA Needs to Follow Best Practices and Procedures When Reorganizing Its Library Network
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Testimony:
Before the Subcommittee on Investigations and Oversight, House
Committee on Science and Technology:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 9:30 a.m.EDT:
Thursday, March 13, 2008:
Environmental Protection:
EPA Needs to Follow Best Practices and Procedures When Reorganizing Its
Library Network:
Statement of John B. Stephenson, Director:
Natural Resources and Environment:
GAO-08-579T:
GAO Highlights:
Highlights of GAO-08-579T, a testimony before the Subcommittee on
Investigations and Oversight, House Committee on Science and
Technology.
Why GAO Did This Study:
Established in 1971, the Environmental Protection Agency‘s (EPA)
library network provides access to critical environmental information
that the agency needs to fulfill its mission of protecting human health
and the environment. The library network also provides information and
services to the public. In fiscal year 2006, the network included 26
libraries across headquarters, regional offices, research centers, and
laboratories. These libraries were independently operated by several
different EPA program offices, depending on the nature of the
libraries‘ collections. In 2006, facing proposed budget cuts, EPA
issued a plan to reorganize the network beginning in fiscal year 2007.
The plan proposed a phased approach to closing libraries and
dispersing, disposing of, and digitizing library materials.
GAO was asked to summarize the findings in its report being released
today, Environmental Protection: EPA Needs to Ensure That Best
Practices and Procedures Are Followed When Making Further Changes to
Its Library Network (GAO-08-304). For this study, GAO reviewed
pertinent EPA policies, plans, and guidance and inter-viewed EPA
officials and staff from each of the 26 libraries. GAO made four
recommendations in this report aimed at best practices and procedures
that EPA should follow when continuing to reorganize its library
network. The agency agreed with the recommendations.
What GAO Found:
Since 2006, EPA has implemented its library reorganization plan and has
closed physical access to the Office of Environmental Information (OEI)
headquarters library and three regional office libraries. In the same
period, six other libraries in the network independently changed their
operations. Some of these libraries digitized, dispersed, or disposed
of their materials before EPA had drafted a common set of agencywide
library procedures for doing so. Until these procedures are completed,
EPA plans no further changes to the library network.
EPA reorganized its library network primarily to generate cost savings
through a more coordinated library network and more electronic delivery
of services. However, GAO found that EPA did not effectively justify
its reorganization decision. According to EPA officials, OEI decided to
reorganize its libraries without fully completing the recommended
analyses in order to reduce its fiscal year 2007 funding in response to
the President‘s fiscal year 2007 budget proposal.
EPA did not systematically inform the full range of stakeholders on the
final configuration of the library network. In addition, 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 effort. EPA is currently reaching out to
stakeholders, including EPA staff and library experts, by holding and
attending stakeholder meetings and conferences.
EPA does not yet 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. 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.
EPA did not follow 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.
The several different program offices responsible for the EPA libraries
in the network each generally decide how much of their available
funding to allocate to their libraries and how to fund their
reorganization. However, when faced with a proposed budget reduction of
$2 million in fiscal year 2007, rather than following its normal
procedures, OEI 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 allocate funds to
help closing libraries manage their collections; instead, the
responsible program or regional office used its annual funding to pay
for these costs.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-579T]. For more information, contact John
B. Stephenson at (202) 512-3841 or stephensonj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I am pleased to appear here today to discuss our recent review of the
reorganization of the Environmental Protection Agency's (EPA) library
network, which is being released today.[Footnote 1] We conducted this
review at the request of the House Committees on Science and
Technology, Oversight and Government Reform, and Energy and Commerce,
and the Senate Committee on Environment and Public Works.
As you know, the 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. 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 2006, the network included 26 libraries across headquarters,
regional offices, research centers, and laboratories, and these
libraries were independently operated by several different EPA program
offices, depending on the nature of the libraries' collections.
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). This plan focused on OEI's
headquarters library and libraries located in each of the agency's 10
regional offices. The plan was intended to provide a framework for
consolidating libraries and making more materials and services
available on line.
My testimony, which is based on our report being released today on the
EPA library network, addresses (1) the status of, and plans for, the
library network reorganization; (2) EPA's rationale for its decision to
reorganize the library network; (3) the extent to which EPA has
communicated with and solicited views from EPA staff and external
stakeholders in planning and implementing the reorganization; (4) the
steps EPA has taken to maintain the quality of library services
following the reorganization, both currently and in the future; and (5)
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. 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.
We conducted this work 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.
Summary:
In summary, we found the following:
* Since 2006, EPA has implemented its library reorganization plan and
closed physical access to the OEI headquarters library and three
regional office libraries. In the same period, six other libraries in
the network independently changed their operations: one closed, four
reduced their hours of operation, and one changed how it provides
library services. Sixteen libraries did not change. Furthermore, some
of these libraries digitized, dispersed, or disposed of their materials
before EPA had drafted a common set of agencywide library procedures
for doing so. Until these procedures are completed, EPA plans no
further changes to the library network. In addition to completing these
procedures, the library network's future configuration and operations
may depend on EPA's response to directions accompanying its fiscal year
2008 appropriation to use $1 million to restore libraries recently
closed and EPA's 2008 library plan, which describes how EPA expects to
operate the library network in the future.
* EPA reorganized its library network primarily to generate cost
savings through a more coordinated library network and more electronic
delivery of services. However, we found that EPA did not effectively
justify its reorganization decision. That is, before launching the
reorganization, EPA did not conduct several analyses, including many
that its own 2004 study of the libraries recommended, as well as a cost-
benefit analysis that the Office of Management and Budget recommends.
According to EPA officials, OEI decided to reorganize its libraries
without completing the recommended analyses in order 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 fiscal year 2007 budget proposal.
* EPA did not systematically inform the full range of stakeholders on
the final configuration of the library network. In addition, 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 effort. 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. EPA is currently reaching
out to stakeholders, including EPA staff and library experts, by
holding and attending stakeholder meetings and conferences.
* EPA does not yet 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. 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.
EPA did not follow 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, EPA did not
determine whether federal property management regulations applied to
the dispersal and disposal of library materials before it closed the
libraries. Instead, EPA provided vague criteria and guidance to its
libraries and did not adequately oversee the process.
* The several different program offices responsible for the EPA
libraries in the network each generally 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. However, when faced with
a proposed budget reduction of $2 million in fiscal year 2007, rather
than following its normal procedures, OEI 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 allocate funds to help closing libraries manage their
collections; instead, the responsible program or regional office 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. While EPA did not track the costs
associated with closing the libraries, it estimated that it spent about
$80,000 through an existing contract to digitize 15,260 titles between
December 2006 and January 2007.
We recommended 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 that ensure that library materials are dispersed
and disposed of consistently and in accordance with federal property
management regulations. EPA agreed with the recommendations made in our
report.
Background:
The EPA library network was established in 1971 to provide staff and
the public with access to environmental information in support of EPA's
mission to protect human health and the environment. The libraries
differ in function, scope of collections, extent of services, and
public access. Before the 2007 reorganization, the network comprised 26
libraries, each funded and managed by several different program offices
at EPA: 1 library was managed by OEI and 10 by regional
offices;[Footnote 2] 8 libraries were located at EPA laboratories
within the Office of Research and Development (ORD), and 2 were within
the Office of Administration and Resources Management (OARM). In
addition, each of the following program offices had 1 library: Office
of the Administrator, Office of General Counsel, Office of Prevention,
Pesticides, and Toxic Substances (OPPTS), Office of Enforcement and
Compliance Assurance, and Office of Air and Radiation. A national
program manager within OEI was responsible for coordinating the major
activities of the entire EPA library network.
Aside from visiting a physical location, the network provides access to
its collections to its staff and to the public through (1) a Web-based
database of library holdings--the Online Library System (OLS); (2)
interlibrary loans from another network library or a public library;
and (3) through a separate online database--the National Environmental
Publications Internet Site (NEPIS). EPA staff also have access to other
information sources--such as online journals, the Federal Register,
news, databases of bibliographic information, and article citations--
from their desktop computers.
EPA began to evaluate its library network in 2003. It developed and
issued studies to determine the value of library services and inform
regional management of their options to support library services beyond
fiscal year 2006.[Footnote 3] EPA also issued an internal report in
November 2005, which offered recommendations on how to maintain an
effective library network if the library support budget were reduced.
After these reports were 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. In August 2006, the steering committee issued the EPA FY 2007
Library Plan: National Framework for the Headquarters and Regional
Libraries.
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.
The plan provided guidelines for EPA staff to determine how the
collections would be managed; noted that OEI libraries in Regions 5, 6,
and 7 would close, and that the headquarters library would close
physical access to its collection but would function as a repository
library, along with the OARM libraries in Cincinnati, Ohio, and
Research Triangle Park, North Carolina. In addition, according to the
plan, EPA is to develop 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.
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. The future of
EPA's library network--its configuration and its operations--are
contingent on final policies and procedures, on EPA's response to
directions accompanying its fiscal year 2008 appropriation, and on
EPA's 2008 library plan.
Owing to the decentralized nature of the EPA library network, each
library decided on its own whether to change its operations. Table 1
shows the operating status of each library in the EPA library network.
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 City, NY;
Operating status of library: Reduced hours of operation[A].
Program office: Regional Office;
Library/location: Region 3 Library/Philadelphia, PA;
Operating status of library: Open[B].
Program office: Regional Office;
Library/location: Region 4 Library/Atlanta, GA;
Operating status of library: Open; Changed the way that library
services are provided.
Program office: Regional Office;
Library/location: Region 5 Library/Chicago, IL;
Operating status of library: Closed physical access[C].
Program office: Regional Office;
Library/location: Region 6 Library/Dallas, TX;
Operating status of library: Closed physical access[C, D].
Program office: Regional Office;
Library/location: Region 7 Library/Kansas City, KS;
Operating status of library: Closed physical access[D].
Program office: Regional Office;
Library/location: Region 8 Library/Denver, CO;
Operating status of library: Open.
Program office: Regional Office;
Library/location: Region 9 Library/San Francisco, CA;
Operating status of library: 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: Open.
Program office: Office of Research and Development;
Library/location: Atlantic Ecology Division Library/Narragansett, RI;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/location: Gulf Ecology Division Library/Gulf Breeze, FL;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/location: Mid-continent Ecology Division Library/Duluth, MN;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/location: Western Ecology Division Library/Corvallis, OR;
Operating status of library: Open.
Program office: Office of Research and Development;
Library/location: Ground Water and Ecosystems Restoration Division
Library/Ada,OK;
Operating status of library: 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
the Office of Research and Development through an interagency
agreement. The library materials for this library are located at
Research Triangle Park, NC, 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]
While EPA's August 2006 library plan noted that three regional
libraries--Regions 5, 6, and 7--and the headquarters library would
close physical access to their libraries, it did not reflect other
changes that occurred, as shown in table 1. 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 all 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 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 or with the
Region 3 library located in Philadelphia, Pennsylvania.[Footnote 4]
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. 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[A]: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Check].
Program office: Regional Office;
Library: Region 5;
Digitized[A]: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: [Empty].
Program office: Regional Office;
Library: Region 6;
Digitized[A]: [Check];
Dispersed to EPA or non-EPA libraries: [Check];
Disposed: Program office: [Empty].
Program office: Regional Office;
Library: Region 7;
Digitized[A]: [Check];
Dispersed to EPA or non-EPA libraries: [Empty];
Disposed: [Empty].
Program office: Office of Prevention, Pesticides, and Toxic Substances;
Library: Chemical Library;
Digitized[A]: [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. At the time of our review, 15,260 titles had been digitized,
and EPA anticipates that a total of about 51,000 unique EPA library
materials from closed and open libraries will be digitized.
In terms of dispersal, EPA's library plan noted that a library choosing
to disperse its materials can send materials to one of the EPA-
designated repositories, other libraries in the library network, EPA
regional record management centers, 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.
Finally, in terms of disposal, the OEI headquarters library and the
OPPTS Chemical Library disposed of some of their materials as a part of
the reorganization. EPA's library plan noted that certain materials not
claimed during the dispersal process could be destroyed. 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.
Recognizing that libraries could function more cohesively as a network,
EPA established a new interim library policy in 2007 and established
uniform governance and management for the network. This interim policy,
among other things, (1) reestablished the National Library Program
Manager position, which was left vacant from 2005 through 2007 and (2)
resulted in 12 draft agencywide library procedures, including
procedures on digitizing and dispersing library materials, 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 moratorium on changes to the network is lifted. The
January 2007 moratorium was imposed in response to congressional and
other concerns, and extended indefinitely in February 2007.
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,[Footnote 5] and on EPA's 2008 library plan. In
an explanatory statement accompanying the fiscal year 2008 Consolidated
Appropriations Act, $1 million was allocated to restore the network of
EPA libraries that were recently closed or consolidated. The
explanatory statement also 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. Separately, EPA officials
told us that they are 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 reorganized its library network primarily to save costs 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.
EPA initiated its 2004 Business Case study because of ongoing budget
uncertainties and because of technological changes in how users obtain
information and how commercial information resources are made
available. While the study concluded that EPA's libraries provide
"substantial value" to the agency and the public, it raised concerns
about EPA's ability to continue services in its present form. As such,
the study recommended that EPA take several actions to foster an
agencywide discussion on the library network's future. In addition,
according to Office of Management and Budget guidance, 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 6] One element of this
analysis is an evaluation of alternatives to consider different methods
of providing services to achieve program objectives.
However, EPA did not fully complete these assessments before it closed
libraries and began to reorganize the network. According to EPA
officials, EPA decided to reorganize its libraries without fully
completing the recommended analyses in order to reduce its fiscal year
2007 funding for the OEI headquarters and regional office libraries by
$2 million. This claimed savings, however, 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
before fiscal year 2007. Furthermore, EPA did not comprehensively
assess library network spending in advance of the $2 million estimation
of budget cuts.
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 before moving forward.
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 7] We have found that an organization's
transformation or merger is strengthened when it (1) makes public
implementation goals and a timeline; (2) 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; and (3) adopts leading
practices, such as those for library services, to build a world-class
organization. While EPA did not fully take these actions during the
library reorganization, it is now reaching out to both EPA staff and
external stakeholders.
EPA's August 2006 library plan did not inform stakeholders on the final
configuration for the library network or implementation goals and a
timeline. Through the 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. However, EPA
did not provide enough information on how the final library network
would be configured or the implementation goals and timeline it would
take to achieve this configuration. For example, EPA did not inform its
staff or the public 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. According to OEI officials,
the plan was intended to provide a framework for how new services would
be provided and not to lay out the network's physical configuration.
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.
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, management in only a few of the regions
solicited views from their regional staff through discussions with
their regional science councils--an employee group located in each
region composed of EPA scientists and technical specialists--or
unions.[Footnote 8] In addition, EPA generally did not communicate with
and solicit views from external stakeholders before and during the
reorganization because it 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 9] 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. Without an
agencywide communication strategy, staff ownership for the changes 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.
Finally, EPA did not solicit views from federal and industry experts
regarding the digitization of library materials and other issues. 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 recently
increased its outreach efforts. For example, EPA asked local unions to
comment on a draft of the 2008 library plan, and attended and presented
information at a stakeholder forum at which a number of professional
library associations were present. Furthermore, OEI started working
with the Federal Library Information Center Committee, a committee
managed by the Library of Congress, to develop a board of advisers that
will respond to EPA administrators and librarians' questions about the
future direction of EPA libraries.
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 yet have a strategy to ensure that library services will
continue and does not know the full effect of the reorganization on
library services. However, several changes it has made may have limited
access to library materials and 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 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 so that the agency
can measure performance and monitor user needs to ensure a successful
reorganization while maintaining quality services. In addition, to
balance the continued delivery of services with merger and
transformation activities, it is essential 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.
Several changes that EPA made to its library network may have impaired
the continued delivery of library materials and services. For example,
because of copyright issues, only unique reports produced by or for EPA
will be digitized in NEPIS--only about 10 percent of EPA's holdings of
books and reports. 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. EPA also does not have a plan to ensure
the continuation of library services for the public, such as state and
local government environmental agencies, environmental groups, and
other nongovernmental organizations.
Furthermore, 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. 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. EPA officials stated that it was unclear whether
library materials, such as books and journals, were subject to federal
property management regulations. EPA officials stated that they will
engage federal property management officials at GSA regarding what
steps should be taken in the future.
EPA Program Offices Are Responsible for Funding Their Libraries and
Their Reorganization Through Their Support Budgets:
The 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. 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 10] 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 allows regional management to decide how to allocate this
funding among the library and other support services, such as
information technology. For fiscal year 2007, OEI management decided to
reduce funding for the OEI headquarters and regional office libraries
by $2 million, from $2.6 million in enacted funding for fiscal year
2006--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. The $2
million reduction 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. The continuing resolution
was enacted after EPA began reorganizing the library network. According
to EPA, OEI restored $500,000 to the library budget in fiscal year 2007
to support reorganization activities.
When planning the reorganization, EPA recognized that the responsible
dispersal, disposal, and digitization of an EPA library collection is a
major project requiring planning, time, and resources. However, 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 available at the end of fiscal year 2006 to pay for
closing costs.
Mr. Chairman, this concludes my prepared statement. I would be happy to
respond to any questions that you and Members of the Subcommittee may
have.
GAO Contact and Staff Acknowledgments:
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this testimony. For further
information about this testimony, please contact John B. Stephenson, at
(202) 512-3841 or at stephensonj@gao.gov. Individuals who contributed
to this statement include Roshni Davé, Ed Kratzer, Nathan A. Morris,
Omari Norman, and Carol Herrnstadt Shulman.
[End of section]
Footnotes:
[1] GAO, Environmental Protection: EPA Needs to Ensure That Best
Practices and Procedures Are Followed When Making Further Changes to
Its Library Network, GAO-08-304 (Washington, D.C.: Feb. 29, 2008).
[2] OEI primarily funds these regional office libraries.
[3] 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).
[4] OARM libraries are located in Cincinnati, Ohio and in Research
Triangle Park, North Carolina. The OARM libraries and the Region 3
library have been designated as 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.
[5] Pub. L. No. 110-161.
[6] 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).
[7] GAO, Results-Oriented Cultures: Implementing Steps to Assist
Mergers and Organizational Transformations, GAO-03-669 (Washington,
D.C.: July 2, 2003). 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.
[8] 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).
[9] 71 Fed. Reg. 54,986 (Sept. 20, 2006).
[10] 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.
[End of section]
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