Environmental Protection: EPA Needs to Ensure That Best
Practices and Procedures Are Followed When Making Further
Changes to Its Library Network (29-FEB-08, GAO-08-304).						 
                                                                 
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.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-304						        
    ACCNO:   A81173						        
  TITLE:     Environmental Protection: EPA Needs to Ensure That
Best Practices and Procedures Are Followed When Making Further
Changes to Its Library Network
							 
     DATE:   02/29/2008 
  SUBJECT:   Cost analysis
             Environmental protection
             Environmental research
             Freedom of information
             Government information dissemination
             Information access
             Information disclosure
             Information management
             Information resources management
             Program management
             Reorganization
             Strategic planning				 

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GAO-08-304

   

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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 Agencyï¿½s (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) EPAï¿½s 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) EPAï¿½s 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. 

EPAï¿½s 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, EPAï¿½s 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. EPAï¿½s 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 GAOï¿½s 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 [email protected]. 

[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: EPAï¿½s Regional Libraries and Centers. 

Date: September 2004; 
Closures/reduction in hours: Region 2ï¿½s 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 3ï¿½s Ft. Meade, MD, library closed to
the public; 
Event: Presidentï¿½s 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 ORDï¿½s 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 OEIï¿½s 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 [email protected]. 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 [email protected]: 

Staff Acknowledgments: 

In addition to the contact named above, Ed Kratzer, Assistant Director; 
Nathan A. Morris; Roshni Davï¿½; 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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