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:   1 library was managed by OEI, 10 libraries were managed by regional  offices, 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, 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.
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.

	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.
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. 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. 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.
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.
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. 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.
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. 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, 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. 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. 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  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. 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. 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. 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. 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. 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.
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. 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.
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. 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.
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.
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. 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. 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  http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-3841 or stephensonj@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made major contributions to this  report are listed in appendix IV.

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. 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.

Appendix II: Key Practices and Implementation Steps for Effective Mergers and Organizational Transformations

	Ensure top leadership drives the transformation.

Define and articulate a succinct and compelling reason for change.
Balance continued delivery of services with merger and transformation  activities.
Establish a coherent mission and integrated strategic  goals to guide the transformation.
Adopt leading practices for results-oriented strategic planning and  reporting.
Focus on a key set of principles and priorities at the  outset of the transformation.
Embed core values in every aspect of the organization to reinforce the  new culture.
Set implementation goals and a timeline to build  momentum and show progress from day one.
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.
Dedicate an implementation team to manage the  transformation process.
Establish networks to support implementation team.
Select high-performing team members.
Use the performance management system to define  responsibility and ensure accountability for change.
Adopt leading practices to implement effective performance  management systems with adequate safeguards.
Establish a communication strategy to create shared  expectations and report related progress.
Communicate early and often to build trust.
Ensure consistency of message.
Encourage two-way communication.
Provide information to meet specific needs of employees.
Involve employees to obtain their ideas and gain their  ownership for the transformation.
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.
Adopt leading practices to build a world-class organization.

Appendix III: Comments from the Environmental Protection Agency

Appendix IV: GAO Contact and Staff Acknowledgments

	Staff Acknowledgments

In addition to the contact named above, Ed Kratzer, Assistant Director;  Nathan A. Morris; Roshni Davé; and Carol Herrnstadt Shulman made key  contributions to this report. Also contributing to this report were Mike  Dolak, Carol Henn, Kunal Malhotra, Bonnie Mueller, Lynn Musser, Omari  Norman, Kim Raheb, Sarah Veale, and Greg Wilmoth.

Summary:
Why GAO Did This Study

Established in 1971, the Environmental Protection Agency's (EPA) library network provides staff and the public with access to environmental information. Its 26 libraries contain a wide range of information and resources and are located at headquarters, regional offices, research centers, and laboratories nationwide. In 2006, EPA issued a plan to reorganize the network beginning in fiscal year 2007. The plan proposed closing libraries and dispersing, disposing of, and digitizing library materials. GAO was asked to assess (1) the status of, and plans for, the network reorganization; (2) EPA's rationale for reorganizing the network; (3) the extent to which EPA has communicated with and solicited the views of EPA staff and external stakeholders in conducting the reorganization; (4) EPA's steps to maintain the quality of library services after the reorganization; and (5) how EPA is funding the network and its reorganization. For this study, GAO reviewed pertinent EPA documents and interviewed EPA officials and staff from each of the libraries.

What GAO Found

Since 2006, EPA has implemented its reorganization plan to close physical access to 4 libraries. In the same period, 6 other libraries in the network decided to change their operations, while 16 have not changed. Some of these libraries have also digitized, dispersed, or disposed of their materials. Since the reorganization, EPA has begun drafting a common set of agencywide library procedures and has hired a program manager for the network. While these procedures are under development, however, EPA has imposed a moratorium on further changes to the network in response to congressional and other expressions of concern. EPA's primary rationale for the library network reorganization was to generate cost savings by creating a more coordinated library network and increasing the electronic delivery of services. However, EPA did not fully follow procedures recommended in a 2004 EPA study of steps that should be taken to prepare for a reorganization. In particular, EPA did not fully evaluate alternative models, and associated costs and benefits, of library services. EPA officials stated that they needed to act quickly to reorganize the library network in response to a proposed fiscal year 2007 funding reduction. EPA did not develop procedures to inform staff and the public on the final configuration of the library network, and EPA libraries varied considerably and were limited in the extent to which they communicated with and solicited views from stakeholders before and during the reorganization effort. In particular, EPA's plan did not include information that the Chemical Library was to close, and EPA did not inform staff or the public until after the fact. EPA's communication procedures were limited or inconsistent because EPA acted quickly to make changes in response to a proposed fiscal year 2007 funding reduction, and because of the decentralized nature of the library network. EPA is currently increasing its communication efforts. EPA does not have a post-reorganization strategy to ensure the continuity of library services and has not yet determined the full effect of the reorganization on library services. Moreover, EPA has recently made several changes that could have impaired user access to library materials and services. For example, EPA did not determine whether federal property management regulations applied to the dispersal and disposal of library materials before it closed the libraries. Furthermore, EPA lacked oversight of the reorganization process and does not have procedures that would allow the agency to measure performance and monitor user needs. Several different EPA offices are responsible for the libraries in the network. Each office generally decides how much funding to allocate to the libraries for which it is responsible and how to fund their reorganization. However, when faced with a proposed budget reduction of $2 million in fiscal year 2007, EPA specifically directed that these offices reduce funding for their libraries and did not specify how to achieve the reduction. Additional funds were not allocated to assist offices in closing their libraries.