In March 2006, EPA announced that it would be closing its Midwest Regional Library, affecting scientists and researchers in Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin.

On June 1, 2006, EPA Library Steering Committee (composed of senior managers from EPA's Program Offices and Regions) released a DRAFT EPA FY 2007 LIBRARY PLAN: National Framework for the Headquarters and Regional Libraries. Closing libraries prior to presenting a plan is one in a series of mistakes EPA administrators would make.

By October 2006, the EPA Headquarters library; the Office of Prevention, Pollution, and Toxic Substances (OPPTS) library; and libraries in Regions 5, 6, and 7 were preparing to close—materials were being boxed in preparation to be sent to Cincinnati for digitization (by an unspecified date). Library staff had reservations about packing up all the materials so quickly; storing these boxes in conference rooms awaiting disposition, possibly with multiple moves, gave rise to additional concerns.

The EPA FY 2007 Library Plan (www.peer.org/docs/epa/06_21_8_library_plan.pdf) identifies key activities to "be implemented to ensure a transition to the new model of providing library services." Rather than portraying the decisions being made with regard to the library as strategic in nature and well-considered over the past few years by experts and stakeholders, closures of selected EPA libraries were declared necessary cost-saving measures. This assertion was questioned by Public Employees for Environmental Responsibility (PEER), a national alliance of local state and federal resource professionals, as the agency acted while Congress was in recess, without waiting for congressional approval of the president's budget (www.peer.org/news/news_id.php?row_id=731).

Congress became engaged when, on Sept. 19, Reps. Gordon, Waxman, and Dingell sent a letter to the Government Accountability Office (GAO) requesting that it examine the administration's plan for restructuring the EPA library network. The letter voiced several concerns and asked that seven questions specifically be addressed (http://sciencedems.house.gov/media/file/forreleases/gordon_epa-libraries_09sep06.pdf):

• How will EPA's plan affect the delivery of information services to agency employees and the public?
• What is the current status of EPA's planned changes to its library system?
• What criteria are being used to decide which materials in the EPA collection will be disposed of or dispersed to other locations?
• What plans have been made, and what funds are available to digitize the paper holdings of these libraries?
• What costs are associated with any replacement of library services that are undertaken by individual program offices?
• What, if any, provisions have been made to ensure that documents required to be available to the public under EPA's statutes (e.g., Superfund) will continue to be accessible as required by law?
• In developing its plan, did EPA solicit input from members of the public that use its library system?

Mistakes Were Made

Clearly, mistakes were made in terms of transparency, procedures, and specificity concerning the decisions made.

Lack of transparency as to how the decision for closing the libraries was made (with limited input from the user community) gave rise to suggestions that the decision was not given the consideration it deserved.

Unclear procedures for dealing with materials in libraries that had closed (both those to be scanned and others to be "discarded," which came to mean offered to other libraries or placed in dumpsters for recycling), as well as inadequate time allotted for that process (i.e., checking the catalog to make certain that other copies existed before disposing of them and revising catalog entries to indicate the documents' new locations in storage for scanning at a future date), made people uneasy about mistakes that could easily be made, with no recourse possible.

Lack of specificity concerning the extent of library closures and reduction of services (to EPA staff and the public), questions concerning availability of funds for the digitization of unique library materials, the number and type of items in the collections that are unique, and the time required to digitize materials in the collections were seen as causes for alarm among the scientific research and library communities. As of today, we are told that 22,000 of 51,000 EPA documents are available to the public via the Web site. According to promises made by EPA administrators, all EPA-unique documents from the five libraries that have been closed should have been available by the end of January 2007; all EPA-unique documents will be available online within 2 years.

EPA administrators have tried to respond to each set of questions posed, but explanations have been partial and often unclear, as if the individuals were unable to adequately explain decisions (or did not see the need for detailed responses). Statements issued by the agency focused on the big picture, such as the positives of modernizing the library network and the benefits for having documents available online, in full text. Both are admirable goals, but professionals—scientists, researchers, and librarians—were wondering how this was going to be accomplished, particularly in the timeframes proposed; they also wondered if there was anyone on staff who understood the complexities of the tasks ahead.

Internal emails shed further light as to the veracity of some of the statements being made by EPA administrators, indicating that those responsible for communicating the case for library closures did not fully appreciate what was going on. EPA staff members were not forewarned of the closures; in several cases, library staffers remained in the dark until the last moment. Those questioning the rationale for the library closures were told that materials in libraries that were being closed would be digitized. Once the issue of copyright was raised, the digitization project was modified to include only unique documents from libraries that were closing that were authored by EPA staff. (Scientists were quick to point out that many unique agency reports were authored by contractors; these are still not to be included in the digital repository due to rights management issues yet to be addressed.) "Citing copyright and other problems, EPA has admitted that large numbers of research materials boxed-up from closed libraries will not be included in NEPIS. [National Environmental Publications Internet Site database] In addition, large portions of crated collections will remain in storage for the foreseeable future," adding to the costs incurred by closing the libraries (www.peer.org/news/news_id.php?row_id=815).

While digitization of unique materials is admirable, whatever the reason (e.g., preservation of unique documents or ubiquitous access to them), internal agency emails show that EPA librarians are having difficulty finding documents utilizing NSCEP/NEPIS, EPA's Gateway to Free Digital & Paper Publications (www.epa.gov/nscep), a system designed for public use—even for documents they know are already in the system! "With nearly one third of its library network now closed, internal and external researchers are frustrated by being forced to rely on balky, incomplete digital inventories" (www.peer.org/news/news_id.php?row_id=815).

EPA Deputy Administrator Marcus Peacock tried to allay those fears, promising that EPA library material would be made available digitally "in the near future," and that "all unique EPA material from all the recently closed physical libraries will be digitized" by January 2007; "EPA-produced documents from all 21 libraries in the agency's network that could be digitized would be accessible through the Internet within two years" (www.commondreams.org/headlines06/1202-01.htm).

Those who questioned the library closures as a cost-saving measure were not satisfied when told that there were sufficient funds to digitize the material, but not to maintain the libraries. Agency spokeswoman Suzanne Ackerman said that "other regions may put their collections into stasis, i.e., neither fully operational nor fully closed, until funding for dispersion is available" (www.govexec.com/dailyfed/1106/110606m1.htm).

Reaching Out to Constituencies

Through the months of December 2006 and January 2007, EPA worked to repair the damage done by not communicating sufficiently with its primary constituencies. EPA officials met with the Union of Concerned Scientists, congressional staffers, and librarians at the American Library Association's (ALA) Midwinter meeting. Six EPA representatives attended ALA's meeting in Seattle, pledging that the agency would "reach out" before making further changes and temporarily halt library closures. This "re-engaged" agency conceded that EPA had not effectively communicated its plans to rely more heavily on electronic documents brought right to your fingertips. Mike Flynn (Office of Environmental Information) "promised that EPA would seek analysis and stakeholder input before making further changes" (www.libraryjournal.com/article/CA6410005.html and www.libraryjournal.com/article/CA6408970.html), but reiterated the importance of modernizing the libraries.

Librarians attending the meeting expressed concern that fewer librarians would mean that the public would spend an awful lot of time searching for documents. Judith Field of Wayne State University, and 1997/98 past president of SLA, highlighted the need for continued outreach to the larger user community of scientists, researchers, and the public. Additional concerns of special librarians were voiced by Stephen Abrams, president-elect of SLA, who applauded the digitization effort but worried about the format of documents, the need for multiple servers to ensure access to digitized materials in case there is a problem, the need to maintain proper rights management for digitized material written by others (e.g., grant products), and the documents' invisibility to Web search engines. Those present might not have been the best individuals to represent EPA, as they acted as if they were hearing these suggestions for the first time.

Congressional Action

Just prior to the election, a group of 17 Democratic senators and one Independent appealed to the Senate Appropriations Committee requesting that it direct the EPA to restore library collections and services "to the status they held as of January 1, 2006." On Nov. 30, ranking members of four committees in the House of Representatives (Science, Government reform, Energy and commerce, and Transportation and infrastructure) wrote to EPA Administrator Stephen Johnson, requesting that EPA brief their its staff members "and provide a written plan to Congress that includes the schedule and procedures that EPA intends to use to govern the disposition of documents, the consolidation of library services, and the transfer of paper and microfiche documents to electronic forms that will be publicly available" (http://sciencedems.house.gov/media/file/forreleases/gordon_epa-libraries_30nov06.pdf).

In an article published by The New York Times on Dec. 8, 2006, ALA president Leslie Burger called on the administration to "immediately reopen the closed libraries" and on Congress to "conduct oversight hearings to reverse these decisions" (http://select.nytimes.com/search/restricted/article?res=F20616FA3C550C7B8CDDAB0994DE404482). [Registration required.]

On Jan. 3, 2007, the Congressional Research Service released a report prepared for Congress— Restructuring EPA's Libraries: Background and Issues for Congress. It contains tables indicating "the location and operating status of the 26 libraries in EPA's network, as of the beginning of FY2007," funding for EPA Libraries, FY 2002 ($7.0 million, enacted) through FY 2007 ($4.5 million, requested). On Jan. 12, The Atlanta Journal-Constitution was able to report that the agency "has no plans to shut down more of its libraries and has ceased destroying duplicative research materials until it answers questions from Congress" (www.ajc.com/blogs/content/shared-blogs/washington/washington/entries/2007/01/12/epa_puts_librar.html?cxntfid=blogs_window_on_washington).

The U.S. Senate Committee on Environment & Public Works (http://epw.senate.gov) held a full committee hearing on the oversight of recent EPA decisions on Feb. 6, 2007. The issues being addressed by three panels of distinguished witnesses all concerned the public's right to know, including the decision to close EPA libraries. (The Webcast has been archived on the Committee's Web site; prepared testimony is available from each witness, as is the majority statement delivered by Sen. Barbara Boxer, D-Calif.

EPA Administrator Johnson was terrific in delivering major EPA talking points regarding modernization of the library network and providing better access of EPA materials to a wider audience, but he was otherwise ill-prepared by his staff. While able to cite individual titles of books and videos that might be questionable as a holding of a technical library—no one questioned whether they had been purchased with government funds or donated for the convenience of EPA staff—he was unaware of the facts regarding the very issue he was there to address: library closures, disposal of materials from these libraries, internal (EPA staff) emails that had already been made public, and the digitization process. Johnson stated that the libraries were closed "because they got barely any visitors," but this is true only for walk-ins to physical facilities and not for phone, email, Web-based, or faxed requests for assistance. (He did not know whether libraries in Atlanta or Fort Meade were currently staffed or open.)

Senators did not pursue detailed questioning regarding the management of the scanned images, which would have been interesting to the library community, represented on the third panel of witnesses by Burger (ALA). Instead, the administrator was asked to respond to thirty or so questions, in writing; he stated that it would take him a month to do so. The senators encouraged "the Agency to develop a realistic plan and budget to provide continued public access to EPA data" (www.sla.org/content/SLA/pressroom/pressrelease/07pr/pr2704.cfm). (Burger called the EPA plan to close the libraries "convoluted," and Sen. Boxer declared that the status of the libraries was "very bizarre.") Johnson assured the committee that the EPA would not be closing any libraries nor disposing of materials until the committee is satisfied.

In her testimony before the committee, Burger also addressed the EPA's lack of openness with regard to digitizing its materials. "Without more detailed information about the EPA's digitization project, we cannot assess whether they are digitizing the most appropriate materials, whether there is appropriate metadata or cataloging to make sure that people can access the digitized materials, and [whether] the technology that will be used to host the digital content and the finding software meets today's standards" (http://blogs.ala.org/districtdispatch.php?title=ala_president_leslie_burger_testifies_be&more=1&c=1&tb=1&pb=1).

We should remember that the EPA is not the only federal agency reviewing its library system. NASA's Goddard Space Flight Center Library in Greenbelt, Md., closed its doors as of Jan. 1, 2007; five regional libraries of the U.S. Forest Service merged administratively to become the National Forest Service Library. Burger indicated that "the EPA libraries have been functioning like a virtual National Library on the Environment. Now that some of these regional libraries and the pesticide library are closed, key links have been removed from the chain, thus weakening the whole system."

Let's not go back to an EPA library network like we had as of Jan. 1, 2006, but move forward in a considered and deliberate manner, employing best practices for a network of libraries and information centers that is suited for the 21st century.