Environmental Protection: EPA Needs to Follow Best Practices and Procedures When Reorganizing Its Library Network
Published: 2008-03-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: Since 2006, EPA has implemented its library reorganization plan and has closed physical access to the Office of Environmental Information (OEI) headquarters library and three regional office libraries. In the same period, six other libraries in the network independently changed their operations. Some of these libraries digitized, dispersed, or disposed of their materials before EPA had drafted a common set of agencywide library procedures for doing so. Until these procedures are completed, EPA plans no further changes to the library network. EPA reorganized its library network primarily to generate cost savings through a more coordinated library network and more electronic delivery of services. However, GAO found that EPA did not effectively justify its reorganization decision. According to EPA officials, OEI decided to reorganize its libraries without fully completing the recommended analyses in order to reduce its fiscal year 2007 funding in response to the President's fiscal year 2007 budget proposal. EPA did not systematically inform the full range of stakeholders on the final configuration of the library network. In addition, EPA libraries varied considerably in the extent to which they communicated with and solicited views from staff, external stakeholders, and experts before and during the reorganization effort. EPA is currently reaching out to stakeholders, including EPA staff and library experts, by holding and attending stakeholder meetings and conferences. EPA does not yet have an effective strategy to ensure the continuity of library services following the reorganization and does not know the full effect of the reorganization on library services. EPA's library plan describes the reorganization effort as a "phased approach," but it does not provide specific goals, timelines, or feedback mechanisms that allow the agency to measure performance and monitor user needs to ensure a successful reorganization while maintaining quality services. EPA did not follow key practices for a successful transformation, even though the agency made several changes to the library network that could have impaired the continued delivery of library materials and services to its staff and the public. The several different program offices responsible for the EPA libraries in the network each generally decide how much of their available funding to allocate to their libraries and how to fund their reorganization. However, when faced with a proposed budget reduction of $2 million in fiscal year 2007, rather than following its normal procedures, OEI directed the regional and headquarters offices to reduce funding for OEI libraries--a reduction of 77 percent for these libraries from the previous fiscal year. EPA did not allocate funds to help closing libraries manage their collections; instead, the responsible program or regional office used its annual funding to pay for these costs.

section_title: Letter
paragraphs: 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. 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.
subsections: section_title: Background
paragraphs: 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; 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. 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.
section_title: Some Libraries Independently Decided to Close, Reduce Their Hours, or Take Other Actions, but the Final Network Configuration Is Still Uncertain
paragraphs: 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.
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.
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.
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, 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.
section_title: EPA Did Not Effectively Justify Its Decision to Reorganize Its Library Network
paragraphs: 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. 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.
section_title: EPA Did Not Fully Inform or Solicit Views from the Full Range of Stakeholders on the Reorganization but Is Now Increasing Its Outreach Efforts
paragraphs: 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 (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. 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.  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.
section_title: EPA Lacks a Strategy to Ensure Continuity of Library Services and Does Not Know Whether Its Actions Have Impaired Access to Environmental Information
paragraphs: 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.
section_title: EPA Program Offices Are Responsible for Funding Their Libraries and Their Reorganization Through Their Support Budgets
paragraphs: 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.  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.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this testimony. For further  information about this testimony, please contact John B. Stephenson, at  (202) 512-3841 or at stephensonj@gao.gov. Individuals who contributed to  this statement include Roshni Davé, Ed Kratzer, Nathan A. Morris, Omari  Norman, and Carol Herrnstadt Shulman.
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