Environmental Protection: EPA Needs to Follow Best Practices and
Procedures When Reorganizing Its Library Network
(13-MAR-08, GAO-08-579T)

Established in 1971, the Environmental Protection Agency's (EPA)
library network provides access to critical environmental
information that the agency needs to fulfill its mission of
protecting human health and the environment. The library network
also provides information and services to the public. In fiscal
year 2006, the network included 26 libraries across
headquarters, regional offices, research centers, and
laboratories. These libraries were independently operated by
several different EPA program offices, depending on the nature
of the libraries' collections. In 2006, facing proposed budget
cuts, EPA issued a plan to reorganize the network beginning in
fiscal year 2007. The plan proposed a phased approach to closing
libraries and dispersing, disposing of, and digitizing library
materials. GAO was asked to summarize the findings in its report
being released today, Environmental Protection: EPA Needs to
Ensure That Best Practices and Procedures Are Followed When
Making Further Changes to Its Library Network (GAO-08-304). GAO
made four recommendations in this report aimed at best practices
and procedures that EPA should follow when continuing to
reorganize its library network. The agency agreed with the
recommendations.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-579T						        
    ACCNO:   A81294						        
  TITLE:     Environmental Protection: EPA Needs to Follow Best
Practices and Procedures When Reorganizing Its Library Network
							 
     DATE:   03/13/2008 
  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-08-579T   



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Testimony: 

Before the Subcommittee on Investigations and Oversight, House 
Committee on Science and Technology: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 9:30 a.m.EDT: 
Thursday, March 13, 2008: 

Environmental Protection: 

EPA Needs to Follow Best Practices and Procedures When Reorganizing Its 
Library Network: 

Statement of John B. Stephenson, Director: 

Natural Resources and Environment: 

GAO-08-579T: 

GAO Highlights: 

Highlights of GAO-08-579T, a testimony before the Subcommittee on 
Investigations and Oversight, House Committee on Science and 
Technology. 

Why GAO Did This Study: 

Established in 1971, the Environmental Protection Agencyï¿½s (EPA) 
library network provides access to critical environmental information 
that the agency needs to fulfill its mission of protecting human health 
and the environment. The library network also provides information and 
services to the public. In fiscal year 2006, the network included 26 
libraries across headquarters, regional offices, research centers, and 
laboratories. These libraries were independently operated by several 
different EPA program offices, depending on the nature of the 
librariesï¿½ collections. In 2006, facing proposed budget cuts, EPA 
issued a plan to reorganize the network beginning in fiscal year 2007. 
The plan proposed a phased approach to closing libraries and 
dispersing, disposing of, and digitizing library materials. 

GAO was asked to summarize the findings in its report being released 
today, Environmental Protection: EPA Needs to Ensure That Best 
Practices and Procedures Are Followed When Making Further Changes to 
Its Library Network (GAO-08-304). For this study, GAO reviewed 
pertinent EPA policies, plans, and guidance and inter-viewed EPA 
officials and staff from each of the 26 libraries. GAO made four 
recommendations in this report aimed at best practices and procedures 
that EPA should follow when continuing to reorganize its library 
network. The agency agreed with the recommendations. 

What GAO Found: 

Since 2006, EPA has implemented its library reorganization plan and has 
closed physical access to the Office of Environmental Information (OEI) 
headquarters library and three regional office libraries. In the same 
period, six other libraries in the network independently changed their 
operations. Some of these libraries digitized, dispersed, or disposed 
of their materials before EPA had drafted a common set of agencywide 
library procedures for doing so. Until these procedures are completed, 
EPA plans no further changes to the library network. 

EPA reorganized its library network primarily to generate cost savings 
through a more coordinated library network and more electronic delivery 
of services. However, GAO found that EPA did not effectively justify 
its reorganization decision. According to EPA officials, OEI decided to 
reorganize its libraries without fully completing the recommended 
analyses in order to reduce its fiscal year 2007 funding in response to 
the Presidentï¿½s fiscal year 2007 budget proposal. 

EPA did not systematically inform the full range of stakeholders on the 
final configuration of the library network. In addition, EPA libraries 
varied considerably in the extent to which they communicated with and 
solicited views from staff, external stakeholders, and experts before 
and during the reorganization effort. EPA is currently reaching out to 
stakeholders, including EPA staff and library experts, by holding and 
attending stakeholder meetings and conferences. 

EPA does not yet have an effective strategy to ensure the continuity of 
library services following the reorganization and does not know the 
full effect of the reorganization on library services. EPAï¿½s library 
plan describes the reorganization effort as a ï¿½phased approach,ï¿½ but it 
does not provide specific goals, timelines, or feedback mechanisms that 
allow the agency to measure performance and monitor user needs to 
ensure a successful reorganization while maintaining quality services. 
EPA did not follow key practices for a successful transformation, even 
though the agency made several changes to the library network that 
could have impaired the continued delivery of library materials and 
services to its staff and the public. 

The several different program offices responsible for the EPA libraries 
in the network each generally decide how much of their available 
funding to allocate to their libraries and how to fund their 
reorganization. However, when faced with a proposed budget reduction of 
$2 million in fiscal year 2007, rather than following its normal 
procedures, OEI directed the regional and headquarters offices to 
reduce funding for OEI librariesï¿½a reduction of 77 percent for these 
libraries from the previous fiscal year. EPA did not allocate funds to 
help closing libraries manage their collections; instead, the 
responsible program or regional office used its annual funding to pay 
for these costs. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-579T]. For more information, contact John 
B. Stephenson at (202) 512-3841 or [email protected]. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to appear here today to discuss our recent review of the 
reorganization of the Environmental Protection Agency's (EPA) library 
network, which is being released today.[Footnote 1] We conducted this 
review at the request of the House Committees on Science and 
Technology, Oversight and Government Reform, and Energy and Commerce, 
and the Senate Committee on Environment and Public Works. 

As you know, the library network provides access to critical 
environmental information that the agency needs to promote 
environmental awareness, conduct research, enforce environmental laws, 
make policy decisions, and fulfill its mission of protecting human 
health and the environment. The library network also provides 
information and services to state environmental agencies, local 
community organizations, and the general public to help these 
stakeholders in protecting human health and the environment. In fiscal 
year 2006, the network included 26 libraries across headquarters, 
regional offices, research centers, and laboratories, and these 
libraries were independently operated by several different EPA program 
offices, depending on the nature of the libraries' collections. 

In fiscal year 2007, EPA began to reorganize its library network on the 
basis of a 2006 reorganization plan issued by EPA's Office of 
Environmental Information (OEI). This plan focused on OEI's 
headquarters library and libraries located in each of the agency's 10 
regional offices. The plan was intended to provide a framework for 
consolidating libraries and making more materials and services 
available on line. 

My testimony, which is based on our report being released today on the 
EPA library network, addresses (1) the status of, and plans for, the 
library network reorganization; (2) EPA's rationale for its decision to 
reorganize the library network; (3) the extent to which EPA has 
communicated with and solicited views from EPA staff and external 
stakeholders in planning and implementing the reorganization; (4) the 
steps EPA has taken to maintain the quality of library services 
following the reorganization, both currently and in the future; and (5) 
how EPA is funding the library network and its reorganization. 

To address these objectives, we reviewed relevant EPA documents, 
policies, plans, and guidance as well as related laws and requirements 
pertinent to the library network and reorganization effort. We 
interviewed EPA librarians and library managers from each of the 26 
libraries in EPA's library network as well as EPA officials 
knowledgeable about EPA's library network and budget. In addition, we 
interviewed representatives from local unions, who represent EPA staff, 
and regional science councils, which is a group that consists of EPA 
scientists and technical specialists. We also sought information from 
library professionals, including representatives from the American 
Library Association and the Association of Research Libraries; members 
of academia; and private consulting companies with expertise in 
libraries. 

We conducted this work from December 2006 through February 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Summary: 

In summary, we found the following: 

* Since 2006, EPA has implemented its library reorganization plan and 
closed physical access to the OEI headquarters library and three 
regional office libraries. In the same period, six other libraries in 
the network independently changed their operations: one closed, four 
reduced their hours of operation, and one changed how it provides 
library services. Sixteen libraries did not change. Furthermore, some 
of these libraries digitized, dispersed, or disposed of their materials 
before EPA had drafted a common set of agencywide library procedures 
for doing so. Until these procedures are completed, EPA plans no 
further changes to the library network. In addition to completing these 
procedures, the library network's future configuration and operations 
may depend on EPA's response to directions accompanying its fiscal year 
2008 appropriation to use $1 million to restore libraries recently 
closed and EPA's 2008 library plan, which describes how EPA expects to 
operate the library network in the future. 

* EPA reorganized its library network primarily to generate cost 
savings through a more coordinated library network and more electronic 
delivery of services. However, we found that EPA did not effectively 
justify its reorganization decision. That is, before launching the 
reorganization, EPA did not conduct several analyses, including many 
that its own 2004 study of the libraries recommended, as well as a cost-
benefit analysis that the Office of Management and Budget recommends. 
According to EPA officials, OEI decided to reorganize its libraries 
without completing the recommended analyses in order to reduce its 
fiscal year 2007 funding by $2 million to create the savings necessary 
for its headquarters library and the regional office libraries, per the 
President's fiscal year 2007 budget proposal. 

* EPA did not systematically inform the full range of stakeholders on 
the final configuration of the library network. In addition, EPA 
libraries varied considerably in the extent to which they communicated 
with and solicited views from staff, external stakeholders, and experts 
before and during the reorganization effort. Such efforts were limited 
or inconsistent because EPA acted quickly to make changes in response 
to a proposed fiscal year 2007 funding reduction and because of the 
decentralized nature of the library network. EPA is currently reaching 
out to stakeholders, including EPA staff and library experts, by 
holding and attending stakeholder meetings and conferences. 

* EPA does not yet have an effective strategy to ensure the continuity 
of library services following the reorganization and does not know the 
full effect of the reorganization on library services. EPA's library 
plan describes the reorganization effort as a "phased approach," but it 
does not provide specific goals, timelines, or feedback mechanisms that 
allow the agency to measure performance and monitor user needs to 
ensure a successful reorganization while maintaining quality services. 
EPA did not follow key practices for a successful transformation, even 
though the agency made several changes to the library network that 
could have impaired the continued delivery of library materials and 
services to its staff and the public. For example, EPA did not 
determine whether federal property management regulations applied to 
the dispersal and disposal of library materials before it closed the 
libraries. Instead, EPA provided vague criteria and guidance to its 
libraries and did not adequately oversee the process. 

* The several different program offices responsible for the EPA 
libraries in the network each generally decide how much of their 
available funding to allocate to their libraries and how to fund their 
reorganization. For example, OEI typically provides funding for the 
regional office libraries through each region's support budget and 
gives regional management discretion on how to allocate this funding 
among the library and other support services. However, when faced with 
a proposed budget reduction of $2 million in fiscal year 2007, rather 
than following its normal procedures, OEI directed the regional and 
headquarters offices to reduce funding for OEI libraries--a reduction 
of 77 percent for these libraries from the previous fiscal year. EPA 
did not allocate funds to help closing libraries manage their 
collections; instead, the responsible program or regional office used 
its annual funding to pay for these costs. Services formerly provided 
by the closed libraries are now provided on a fee-for-service basis by 
other libraries in the network. While EPA did not track the costs 
associated with closing the libraries, it estimated that it spent about 
$80,000 through an existing contract to digitize 15,260 titles between 
December 2006 and January 2007. 

We recommended that the Administrator of EPA continue the agency's 
moratorium on changes to the library network until the agency (1) 
develops a strategy to justify its reorganization plans; (2) improves 
its outreach efforts; (3) ensures sufficient oversight and control over 
the reorganization process, and continuously and consistently monitors 
the impact of the reorganization on EPA staff and the public; and (4) 
implements procedures that ensure that library materials are dispersed 
and disposed of consistently and in accordance with federal property 
management regulations. EPA agreed with the recommendations made in our 
report. 

Background: 

The EPA library network was established in 1971 to provide staff and 
the public with access to environmental information in support of EPA's 
mission to protect human health and the environment. The libraries 
differ in function, scope of collections, extent of services, and 
public access. Before the 2007 reorganization, the network comprised 26 
libraries, each funded and managed by several different program offices 
at EPA: 1 library was managed by OEI and 10 by regional 
offices;[Footnote 2] 8 libraries were located at EPA laboratories 
within the Office of Research and Development (ORD), and 2 were within 
the Office of Administration and Resources Management (OARM). In 
addition, each of the following program offices had 1 library: Office 
of the Administrator, Office of General Counsel, Office of Prevention, 
Pesticides, and Toxic Substances (OPPTS), Office of Enforcement and 
Compliance Assurance, and Office of Air and Radiation. A national 
program manager within OEI was responsible for coordinating the major 
activities of the entire EPA library network. 

Aside from visiting a physical location, the network provides access to 
its collections to its staff and to the public through (1) a Web-based 
database of library holdings--the Online Library System (OLS); (2) 
interlibrary loans from another network library or a public library; 
and (3) through a separate online database--the National Environmental 
Publications Internet Site (NEPIS). EPA staff also have access to other 
information sources--such as online journals, the Federal Register, 
news, databases of bibliographic information, and article citations-- 
from their desktop computers. 

EPA began to evaluate its library network in 2003. It developed and 
issued studies to determine the value of library services and inform 
regional management of their options to support library services beyond 
fiscal year 2006.[Footnote 3] EPA also issued an internal report in 
November 2005, which offered recommendations on how to maintain an 
effective library network if the library support budget were reduced. 
After these reports were issued, EPA established a Library Steering 
Committee--composed of senior managers from EPA's program offices and 
regions--to develop a new model for providing library services to EPA 
staff. In August 2006, the steering committee issued the EPA FY 2007 
Library Plan: National Framework for the Headquarters and Regional 
Libraries. 

The August 2006 library plan provided the framework for the network to 
begin reorganizing in the summer of 2006 in preparation for the 
proposed fiscal year 2007 budget reduction beginning in October 2006. 
The plan provided guidelines for EPA staff to determine how the 
collections would be managed; noted that OEI libraries in Regions 5, 6, 
and 7 would close, and that the headquarters library would close 
physical access to its collection but would function as a repository 
library, along with the OARM libraries in Cincinnati, Ohio, and 
Research Triangle Park, North Carolina. In addition, according to the 
plan, EPA is to develop Library Centers of Excellence, where a library 
with more expertise in a specific area of reference research would 
provide that service to staff in other regions. 

Some Libraries Independently Decided to Close, Reduce Their Hours, or 
Take Other Actions, but the Final Network Configuration Is Still 
Uncertain: 

As a part of EPA's 2006 reorganization effort, some EPA libraries have 
closed, reduced their hours of operation, or changed the way that they 
provide library services. Furthermore, some of these libraries have 
digitized, dispersed, or disposed of their materials. The future of 
EPA's library network--its configuration and its operations--are 
contingent on final policies and procedures, on EPA's response to 
directions accompanying its fiscal year 2008 appropriation, and on 
EPA's 2008 library plan. 

Owing to the decentralized nature of the EPA library network, each 
library decided on its own whether to change its operations. Table 1 
shows the operating status of each library in the EPA library network. 

Table 1: Operating Status of Each Library in the EPA Library Network: 

Program office: Office of Environmental Information; 
Library/location: Headquarters Library/Washington, DC; 
Operating status of library: Closed physical access; Serves as a 
repository library. 

Program office: Regional Office; 
Library/location: Region 1 Library/Boston, MA;
Operating status of library: Reduced hours of operation. 

Program office: Regional Office; 
Library/location: Region 2 Library/New York City, NY; 
Operating status of library: Reduced hours of operation[A]. 

Program office: Regional Office; 
Library/location: Region 3 Library/Philadelphia, PA; 
Operating status of library: Open[B]. 

Program office: Regional Office; 
Library/location: Region 4 Library/Atlanta, GA; 
Operating status of library: Open; Changed the way that library 
services are provided. 

Program office: Regional Office; 
Library/location: Region 5 Library/Chicago, IL; 
Operating status of library: Closed physical access[C]. 

Program office: Regional Office; 
Library/location: Region 6 Library/Dallas, TX; 
Operating status of library: Closed physical access[C, D]. 

Program office: Regional Office; 
Library/location: Region 7 Library/Kansas City, KS; 
Operating status of library: Closed physical access[D]. 

Program office: Regional Office; 
Library/location: Region 8 Library/Denver, CO; 
Operating status of library: Open. 

Program office: Regional Office; 
Library/location: Region 9 Library/San Francisco, CA; 
Operating status of library: Reduced hours of operation. 

Program office: Regional Office; 
Library/location: Region 10 Library/Seattle, WA; 
Operating status of library: Reduced hours of operation. 

Program office: Office of Prevention, Pesticides, and Toxic Substances; 
Library/location: Chemical Library/Washington, DC; 
Operating status of library: Closed physical access[C]. 

Program office: Office of Administration and Resources Management; 
Library/location: Andrew Breidenbach Environmental Research Center/ 
Cincinnati, OH; 
Operating status of library: Open; Serves as a repository library. 

Program office: Office of Administration and Resources Management; 
Library/location: Research Triangle Park Library Service/Research 
Triangle Park, NC; 
Operating status of library: Open; Serves as a repository library. 

Program office: Office of Enforcement and Compliance Assurance; 
Library/location: National Enforcement Investigations Center 
Environmental Forensics Library/Denver, CO; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Environmental Sciences Division Technical Research 
Center/Las Vegas, NV; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Ecosystem Research Division Library/Athens, GA; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Atlantic Ecology Division Library/Narragansett, RI; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Gulf Ecology Division Library/Gulf Breeze, FL; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Mid-continent Ecology Division Library/Duluth, MN; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Western Ecology Division Library/Corvallis, OR; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Ground Water and Ecosystems Restoration Division 
Library/Ada,OK; 
Operating status of library: Open. 

Program office: Office of Research and Development; 
Library/location: Atmospheric Sciences Modeling Division Library/ 
Research Triangle Park, NC; 
Operating status of library: Open[E]. 

Program office: Office of the Administrator; 
Library/location: Legislative Reference Library/Washington, DC; 
Operating status of library: Open. 

Program office: Office of General Counsel; 
Library/location: Law Library/Washington, DC; 
Operating status of library: Open. 

Program office: Office of Air and Radiation; 
Library/location: National Vehicle and Fuel Emissions Laboratory 
Library/Ann Arbor, MI; 
Operating status of library: Open. 

Source: GAO analysis of EPA data. 

[A] A library located at an Edison, New Jersey, laboratory in Region 2 
closed in September 2004. This library closure preceded the closures 
associated with the fiscal year 2007 library network reorganization. 
Although this library was managed separately and independently from the 
Region 2 library, the materials from this library were transferred to 
the main Region 2 library in New York, New York, when the library 
closed. Librarians from the main library in Region 2 now provide 
library services to Edison, New Jersey, staff. 

[B] The lone librarian in Region 3's satellite library in Ft. Meade, 
Maryland, resigned in February 2006. The Ft. Meade library's collection 
remains in place and is open for EPA staff use, although no staff 
manage the collection. Librarians from the main library in Region 3, 
located in Philadelphia, Pennsylvania, now provide library services to 
Ft. Meade staff. According to EPA officials, the Ft. Meade library was 
closed to the public because the library did not receive many visits 
from the public, and because the library was located at a high-security 
military base. 

[C] The libraries in Regions 5 and 6 and the Chemical Library reduced 
their hours of operation for a period of time prior to closing. 

[D] The libraries in Regions 6 and 7, although closed to physical 
access, still contain library materials on shelves because of the 
moratorium on further changes to the network that was placed in January 
2007. According to EPA officials, materials from the Regions 6 and 7 
libraries are not accessible to walk-in traffic but remain accessible 
through interlibrary loan. 

[E] The Atmospheric Sciences Modeling Division library was funded by 
the National Oceanic and Atmospheric Administration but run jointly by 
the Office of Research and Development through an interagency 
agreement. The library materials for this library are located at 
Research Triangle Park, NC, and managed by OARM library staff. In 
fiscal year 2008, the library was not funded and will be consolidated 
into the OARM Research Triangle Park library once the moratorium is 
lifted, according to EPA officials. 

[End of table] 

While EPA's August 2006 library plan noted that three regional 
libraries--Regions 5, 6, and 7--and the headquarters library would 
close physical access to their libraries, it did not reflect other 
changes that occurred, as shown in table 1. According to EPA officials, 
the plan focused on the OEI headquarters and regional office libraries, 
and they did not think it was necessary to reflect all changes that 
were planned for other libraries. The focus of the plan, according to 
EPA officials, was to set the framework on how library services would 
be provided electronically and not on what physical changes were to 
occur. 

Although no longer accessible to walk-in traffic from EPA staff and the 
public, the closed regional and headquarters libraries continue to 
provide library services, such as interlibrary loans and research/ 
reference requests, to EPA staff through service agreements that the 
closed libraries established with libraries managed by OARM or with the 
Region 3 library located in Philadelphia, Pennsylvania.[Footnote 4] 

As part of the library reorganization, each library in the network that 
was planning to close access to walk-in services independently decided 
which materials would be retained at their library or be selected for 
digitization, dispersal to EPA or non-EPA libraries, or disposal. Table 
2 shows the actions taken by the closed libraries. 

Table 2: Current Status of Materials at Closed Libraries: 

Program office: Office of Environmental Information; 
Library: Headquarters; 
Digitized[A]: [Check]; 
Dispersed to EPA or non-EPA libraries: [Check]; 
Disposed: [Check]. 

Program office: Regional Office; 
Library: Region 5; 
Digitized[A]: [Check]; 
Dispersed to EPA or non-EPA libraries: [Check]; 
Disposed: [Empty]. 

Program office: Regional Office; 
Library: Region 6; 
Digitized[A]: [Check]; 
Dispersed to EPA or non-EPA libraries: [Check]; 
Disposed: Program office: [Empty]. 

Program office: Regional Office; 
Library: Region 7; 
Digitized[A]: [Check]; 
Dispersed to EPA or non-EPA libraries: [Empty]; 
Disposed: [Empty]. 

Program office: Office of Prevention, Pesticides, and Toxic Substances; 
Library: Chemical Library; 
Digitized[A]: [B]; 
Dispersed to EPA or non-EPA libraries: [Check]; 
Disposed: [Check]. 

Source: GAO analysis of EPA data. 

[A] In addition to the closed libraries, libraries in Regions 2 and 3, 
and the Atmospheric Sciences Modeling Division library in Research 
Triangle Park, North Carolina, also digitized materials. 

[B] The OPPTS Chemical Library has developed a list of materials to be 
digitized but has not yet digitized any materials because of the 
moratorium on further changes to the library network, and because EPA's 
digitization procedures are undergoing third-party review. While these 
materials sit in boxes in the headquarters repository library and the 
OPPTS Chemical Library, EPA officials told us the materials can be 
identified and retrieved if a request arises. 

[End of table] 

In terms of digitization, the criteria in the August 2006 library plan 
noted that unique EPA materials--which, according to EPA officials, 
refers to materials created by or for EPA--that are not already 
electronically available in NEPIS would be digitized and made available 
in NEPIS. At the time of our review, 15,260 titles had been digitized, 
and EPA anticipates that a total of about 51,000 unique EPA library 
materials from closed and open libraries will be digitized. 

In terms of dispersal, EPA's library plan noted that a library choosing 
to disperse its materials can send materials to one of the EPA- 
designated repositories, other libraries in the library network, EPA 
regional record management centers, other federal agency libraries, 
state libraries and state environmental agency libraries, colleges and 
university libraries, public libraries, or e-mail networks used 
specifically to exchange library materials. 

Finally, in terms of disposal, the OEI headquarters library and the 
OPPTS Chemical Library disposed of some of their materials as a part of 
the reorganization. EPA's library plan noted that certain materials not 
claimed during the dispersal process could be destroyed. In total, the 
OEI headquarters library has disposed of over 800 journals and books, 
and the Chemical Library has disposed of over 3,000 journals and books. 

Recognizing that libraries could function more cohesively as a network, 
EPA established a new interim library policy in 2007 and established 
uniform governance and management for the network. This interim policy, 
among other things, (1) reestablished the National Library Program 
Manager position, which was left vacant from 2005 through 2007 and (2) 
resulted in 12 draft agencywide library procedures, including 
procedures on digitizing and dispersing library materials, and 
developing a communication strategy. EPA officials told us that they do 
not have a time frame for completing these procedures but will complete 
them before the moratorium on changes to the network is lifted. The 
January 2007 moratorium was imposed in response to congressional and 
other concerns, and extended indefinitely in February 2007. 

The future of the library network, its configuration, and its 
operations are contingent on the completion of the final policies and 
procedures, on EPA's response to directions accompanying its fiscal 
year 2008 appropriation,[Footnote 5] and on EPA's 2008 library plan. In 
an explanatory statement accompanying the fiscal year 2008 Consolidated 
Appropriations Act, $1 million was allocated to restore the network of 
EPA libraries that were recently closed or consolidated. The 
explanatory statement also directed EPA to submit a plan to the 
Committees on Appropriations within 90 days of enactment regarding 
actions it will take to restore the network. Separately, EPA officials 
told us that they are developing a Library Strategic Plan for 2008 and 
Beyond, which details EPA's library services for staff and the public 
and a vision for the future of the library network. 

EPA Did Not Effectively Justify Its Decision to Reorganize Its Library 
Network: 

EPA reorganized its library network primarily to save costs by creating 
a more coordinated library network and increasing the electronic 
delivery of library services. However, EPA did not fully complete 
several analyses, including many that its 2004 study recommended. In 
addition, EPA's decision to reorganize its library network was not 
based on a thorough analyses of the costs and benefits associated with 
such a reorganization. 

EPA initiated its 2004 Business Case study because of ongoing budget 
uncertainties and because of technological changes in how users obtain 
information and how commercial information resources are made 
available. While the study concluded that EPA's libraries provide 
"substantial value" to the agency and the public, it raised concerns 
about EPA's ability to continue services in its present form. As such, 
the study recommended that EPA take several actions to foster an 
agencywide discussion on the library network's future. In addition, 
according to Office of Management and Budget guidance, a benefit-cost 
analysis should be conducted to support decisions to initiate, renew, 
or expand programs or projects, and that in conducting such an 
analysis, tangible and intangible benefits and costs should be 
identified, assessed, and reported.[Footnote 6] One element of this 
analysis is an evaluation of alternatives to consider different methods 
of providing services to achieve program objectives. 

However, EPA did not fully complete these assessments before it closed 
libraries and began to reorganize the network. According to EPA 
officials, EPA decided to reorganize its libraries without fully 
completing the recommended analyses in order to reduce its fiscal year 
2007 funding for the OEI headquarters and regional office libraries by 
$2 million. This claimed savings, however, was not substantiated by any 
formal EPA cost assessment. According to EPA officials, the $2 million 
funding reduction was informally estimated in 2005 with the expectation 
that EPA would have been further along in its library reorganization 
before fiscal year 2007. Furthermore, EPA did not comprehensively 
assess library network spending in advance of the $2 million estimation 
of budget cuts. 

By not completing a full assessment of its library resources and not 
conducting a benefit-cost analysis of various approaches to 
reorganizing the network, EPA did not justify the reorganization 
actions in a way that fully considered and ensured adequate support for 
the mission of the library network, the continuity of services provided 
to EPA staff and the public, the availability of EPA materials to a 
wider audience, and the potential cost savings. In effect, EPA 
attempted to achieve cost savings without (1) first determining whether 
potential savings were available and (2) performing the steps that its 
own study specified as necessary before moving forward. 

EPA Did Not Fully Inform or Solicit Views from the Full Range of 
Stakeholders on the Reorganization but Is Now Increasing Its Outreach 
Efforts: 

Communicating with and soliciting views from staff and other 
stakeholders are key components of successful mergers and 
transformations.[Footnote 7] We have found that an organization's 
transformation or merger is strengthened when it (1) makes public 
implementation goals and a timeline; (2) establishes an agencywide 
communication strategy and involves staff to obtain their ideas, which 
among other things, involves communicating early and often to build 
trust, ensuring consistency of message, and incorporating staff 
feedback into new policies and procedures; and (3) adopts leading 
practices, such as those for library services, to build a world-class 
organization. While EPA did not fully take these actions during the 
library reorganization, it is now reaching out to both EPA staff and 
external stakeholders. 

EPA's August 2006 library plan did not inform stakeholders on the final 
configuration for the library network or implementation goals and a 
timeline. Through the library plan, EPA generally informed internal and 
external stakeholders of its vision for the reorganized library 
network, noting that EPA would be moving toward a new model of 
providing library services to EPA staff and the public. However, EPA 
did not provide enough information on how the final library network 
would be configured or the implementation goals and timeline it would 
take to achieve this configuration. For example, EPA did not inform its 
staff or the public that OPPTS would close its Chemical Library and 
that other libraries would reduce their hours of operation or make 
other changes to their library services. According to OEI officials, 
the plan was intended to provide a framework for how new services would 
be provided and not to lay out the network's physical configuration. 
Without a clear picture of what EPA intends to achieve with the library 
network reorganization and the implementation goals and timeline to 
achieve this intended outcome, EPA staff may not know if progress is 
being made, which could limit support for the network reorganization. 

Because EPA's library structure was decentralized, EPA did not have an 
agencywide communication strategy to inform EPA staff of, and solicit 
their views on, the changes occurring in the library network, leaving 
that responsibility to each EPA library. As a result, EPA libraries 
varied considerably in the information they provided to staff on 
library changes. For example, management in only a few of the regions 
solicited views from their regional staff through discussions with 
their regional science councils--an employee group located in each 
region composed of EPA scientists and technical specialists--or 
unions.[Footnote 8] In addition, EPA generally did not communicate with 
and solicit views from external stakeholders before and during the 
reorganization because it was moving quickly to make changes in 
response to proposed funding cuts. Of the libraries that closed, only 
the headquarters library informed the public of the changes occurring 
at its library by posting a notification in the Federal Register. 
[Footnote 9] EPA also did not fully communicate with and solicit views 
from professional library associations while planning and implementing 
its library reorganization. EPA did meet with the American Library 
Association, a professional library association, on a few occasions, 
but did so later in the reorganization planning process. Without an 
agencywide communication strategy, staff ownership for the changes may 
be limited, and staff may be confused about the changes. Furthermore, 
EPA cannot be sure that the changes are meeting the needs of EPA staff 
and external stakeholders. 

Finally, EPA did not solicit views from federal and industry experts 
regarding the digitization of library materials and other issues. These 
experts could have provided leading practice information and guidance 
on digitization processes and standards for library materials. As such, 
EPA cannot be sure that it is using leading practices for library 
services. 

Recognizing the need to communicate with and solicit the views of 
staff, external stakeholders, and industry experts, EPA recently 
increased its outreach efforts. For example, EPA asked local unions to 
comment on a draft of the 2008 library plan, and attended and presented 
information at a stakeholder forum at which a number of professional 
library associations were present. Furthermore, OEI started working 
with the Federal Library Information Center Committee, a committee 
managed by the Library of Congress, to develop a board of advisers that 
will respond to EPA administrators and librarians' questions about the 
future direction of EPA libraries. 

EPA Lacks a Strategy to Ensure Continuity of Library Services and Does 
Not Know Whether Its Actions Have Impaired Access to Environmental 
Information: 

EPA does not yet have a strategy to ensure that library services will 
continue and does not know the full effect of the reorganization on 
library services. However, several changes it has made may have limited 
access to library materials and services. According to our review of 
key practices and implementation steps to assist mergers and 
organizational transformations, organizations that are undergoing 
change should seek and monitor staff attitudes and take the appropriate 
follow-up actions. While EPA's library plan describes the 
reorganization effort as a "phased approach," it does not provide 
specific goals, timelines, or feedback mechanisms so that the agency 
can measure performance and monitor user needs to ensure a successful 
reorganization while maintaining quality services. In addition, to 
balance the continued delivery of services with merger and 
transformation activities, it is essential that top leadership drives 
the transformation. However, during the reorganization, EPA did not 
have a national program manager for the library network to oversee and 
guide the reorganization effort. 

Several changes that EPA made to its library network may have impaired 
the continued delivery of library materials and services. For example, 
because of copyright issues, only unique reports produced by or for EPA 
will be digitized in NEPIS--only about 10 percent of EPA's holdings of 
books and reports. If the material is not available electronically, EPA 
staff in locations where libraries have closed will receive the 
material through an interlibrary loan--delaying access to the materials 
from 1 day to up to 20 days. EPA also does not have a plan to ensure 
the continuation of library services for the public, such as state and 
local government environmental agencies, environmental groups, and 
other nongovernmental organizations. 

Furthermore, EPA may have inadvertently limited access to information 
because it did not determine whether federal property management 
regulations applied to the dispersal and disposal of library materials 
and hence may have disposed of materials that should have been 
retained. For example, the Regions 5 and 6 libraries gave materials to 
private companies, and the OEI headquarters library and the Chemical 
Library discarded materials without first determining that they had no 
monetary value. EPA officials stated that it was unclear whether 
library materials, such as books and journals, were subject to federal 
property management regulations. EPA officials stated that they will 
engage federal property management officials at GSA regarding what 
steps should be taken in the future. 

EPA Program Offices Are Responsible for Funding Their Libraries and 
Their Reorganization Through Their Support Budgets: 

The program offices responsible for the EPA libraries in the network 
generally decide how much of their available funding to allocate to 
their libraries out of larger accounts that support multiple 
activities. Until fiscal year 2007, library spending had remained 
relatively stable, ranging from about $7.14 million to $7.85 million 
between fiscal years 2002 and 2006.[Footnote 10] OEI, which is the 
primary source of funding for the regional libraries, typically 
provides funding for them through each region's support budget, and 
generally allows regional management to decide how to allocate this 
funding among the library and other support services, such as 
information technology. For fiscal year 2007, OEI management decided to 
reduce funding for the OEI headquarters and regional office libraries 
by $2 million, from $2.6 million in enacted funding for fiscal year 
2006--a 77-percent reduction for these libraries and a 28-percent 
reduction in total library funding. After $500,000 of the $2 million 
reduction was applied to the headquarters library, the regional 
administrators together decided that the remaining $1.5 million 
reduction should be spread equally across all regions, rather than by 
staffing ratios in each region or previous years' spending. The $2 
million reduction for the libraries was included in the President's 
fiscal year 2007 budget proposal for EPA. However, like most agencies, 
EPA was included in the full-year continuing resolution, which held 
appropriations near fiscal year 2006 levels. The continuing resolution 
was enacted after EPA began reorganizing the library network. According 
to EPA, OEI restored $500,000 to the library budget in fiscal year 2007 
to support reorganization activities. 

When planning the reorganization, EPA recognized that the responsible 
dispersal, disposal, and digitization of an EPA library collection is a 
major project requiring planning, time, and resources. However, EPA did 
not allocate funds specifically to help the closing libraries manage 
their collections. According to EPA, the funding for library closures 
was taken into account during the budget process. As a result, the 
program or regional office responsible for the library used its usual 
library funding available at the end of fiscal year 2006 to pay for 
closing costs. 

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions that you and Members of the Subcommittee may 
have. 

GAO Contact and Staff Acknowledgments: 

Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this testimony. For further 
information about this testimony, please contact John B. Stephenson, at 
(202) 512-3841 or at [email protected]. Individuals who contributed 
to this statement include Roshni Davï¿½, Ed Kratzer, Nathan A. Morris, 
Omari Norman, and Carol Herrnstadt Shulman. 

[End of section] 

Footnotes: 

[1] GAO, Environmental Protection: EPA Needs to Ensure That Best 
Practices and Procedures Are Followed When Making Further Changes to 
Its Library Network, GAO-08-304 (Washington, D.C.: Feb. 29, 2008). 

[2] OEI primarily funds these regional office libraries. 

[3] U.S. Environmental Protection Agency, Office of Environmental 
Information, Business Case for Information Services: EPA's Regional 
Libraries and Centers, EPA 260-R-04-001 (January 2004); and Optional 
Approaches to U.S. EPA Regional Library Support, EPA 260-R-05-002 (June 
2005). 

[4] OARM libraries are located in Cincinnati, Ohio and in Research 
Triangle Park, North Carolina. The OARM libraries and the Region 3 
library have been designated as Centers of Excellence for the EPA 
library network, meaning that these libraries have staff qualified to 
conduct research in specific areas, have access to tools to support 
services, and have the ability to handle increased workload. According 
to EPA officials, the OARM libraries serve as Centers of Excellence for 
core library services, such as research requests and interlibrary 
loans, and the Region 3 library serves as a Center of Excellence for 
business research issues. 

[5] Pub. L. No. 110-161. 

[6] Office of Management and Budget, Guidelines and Discount Rates for 
Benefit-Cost Analysis of Federal Programs, OMB Circular A-94 
(Washington, D.C.: Oct. 29, 1992). 

[7] GAO, Results-Oriented Cultures: Implementing Steps to Assist 
Mergers and Organizational Transformations, GAO-03-669 (Washington, 
D.C.: July 2, 2003). This report identified nine key practices and 
related implementation steps that have led to successful mergers and 
transformations in large private and public sector organizations. 

[8] In September 2007, the national EPA union held arbitration talks 
with EPA. The EPA union won its unfair labor practice claim against the 
agency. More specifically, the Federal Labor Relations Authority 
administrative law judge ruled that EPA violated federal labor law by 
failing to enter arbitration with the union regarding its grievance 
about the library restructuring. U.S. Environmental Protection Agency 
v. American Federation of Government Employees. The ruling also 
required the agency to post signs notifying employees that EPA had 
violated labor law. On February 15, 2008, an arbitrator found that EPA 
had violated provisions of the Master Collective Bargaining Agreement 
by not engaging the union in impact and implementation bargaining 
pertaining to the reorganization of its library network. EPA v. 
American Federation of Government Employees Council 238, FMCS Case No. 
07-50725 (George Edward Larney, Arbitrator). 

[9] 71 Fed. Reg. 54,986 (Sept. 20, 2006). 

[10] These figures are based on estimates from EPA. We did not 
independently determine their accuracy. Because EPA does not track 
library funding, each library in the network provided estimates that 
were based on past spending and enacted funding. However, libraries may 
have varied in the type of spending data provided in terms of whether 
the data included contract costs, salaries, and acquisitions. 

[End of section] 

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