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EPA Library Closures: Management Incompetence or Something More Sinister?
Posted On March 17, 2008
The Government Accountability Office (GAO) has just issued a report analyzing the reorganization of the Environmental Protection Agency (EPA) library network. The GAO found "extensive problems with how EPA implemented the library closures" and questions any cost savings as a result of these efforts to consolidate ( "The report also noted that the EPA does not have an effective strategy to ensure the continuity of library services following the closure of these libraries and EPA does not know the full effect the closures will have on library services" because it does not have the requisite outreach in place to all stakeholder communities. Commenting on the GAO report, Rep. Henry A. Waxman, D-Ca., said that "EPA rushed to close libraries with little notice or input and disregarded concerns raised by EPA employees. …" Sen. Barbara Boxer, D-Ca., questions the price the nation will pay for these closures.1

What Led to the GAO Investigation?

One year ago, the U.S. Senate Committee on Environment & Public Works ( held a full committee hearing on oversight of decisions of the EPA, including the one to close the EPA libraries. (For further information about that hearing, chaired by Sen. Boxer, refer to the Feb. 12, 2007, NewsBreak at Testimony during that session raised more questions than it answered, and EPA Administrator Stephen L. Johnson was asked to respond to additional inquiries in writing.

Wasting no time, Rep. Bart Gordon, D-Tenn. (Chairman of the U.S. House Committee on Science and Technology), Rep. John Dingell, D-Mich. (Chairman of the Committee on Energy and Commerce), Rep. Waxman (Chairman of the Committee on Oversight and Government Reform), and Sen. Boxer formally requested that the GAO investigate the library closings. The GAO was asked to assess the following:

  • The status of the library network reorganization and plans for the future
  • EPA rationale for the reorganization
  • EPA communication with stakeholders, including staff, in conducting the reorganization
  • EPA's steps to maintain quality post-reorganization
  • EPA funding for the network and reorganization

The report just issued is an indictment of the EPA decision-making process:

  • Each EPA region came to its own decision as to how budget cuts for the library network would affect its library, e.g., reduced hours, reduced staffing, reduced services, or closure
  • Each EPA library independently decided which materials should be selected for digitization, dispersal, or disposal
  • The final library network configuration remains unclear as procedures and strategic plans remain in draft phase
  • EPA did not effectively justify its library network reorganization
  • The agency did not fully inform or solicit views from the full range of stakeholders, including staff and experts, though its outreach efforts have improved in the last year
  • EPA does not have a mechanism in place to ascertain how these changes have "impaired access to environmental information"
  • EPA program offices are responsible for funding their libraries and their reorganization

The Hearings

The Subcommittee on Investigations and Oversight of the House Science and Technology Committee held hearings on March 13 "on EPA's plan to consolidate and modernize its library network and the impacts of their implementation of this plan on EPA employees and the public."2 In his opening statement, Chairman Gordon summarized the GAO report on EPA library closings as "a blueprint of how not to modernize and restructure a functioning organization … GAO's report documents the Agency's failure to do any of the work necessary to ensure their stated goal for the modernization would be accomplished. EPA executed a failed process for modernizing their library network. The only goal they accomplished was to reduce the number of libraries in the EPA network. This is not a goal that serves the public or the Agency's mission."3

Subcommittee Chairman Brad Miller's, D-Tenn., opening statement made note that "EPA managers had quietly begun studying how to consolidate and modernize their library system in 2003" and "developed a thoughtful plan" which they summarily ignored "and simply shuttered libraries … Headquarters simply announced a $2 million cut—leaving just $500,000 across the regional system—and left it to the regions to figure out what to do."4 Little guidance was provided. Witnesses came forward to testify how changes made in the library network were affecting EPA government employees, scientists, and librarians, with a response from EPA management.

Witness Testimony and Questioning

Testimony began with John Stephenson, director of Natural Resources and Environment, Government Accountability Office, summarizing the GAO's findings, emphasizing that this agency (indeed, all federal agencies) should follow best practices and procedures when making changes of this nature, in closing libraries and/or establishing and maintaining an electronic library. The GAO found three areas in particular where EPA management had come up short:

Cost-benefit analysis: EPA purportedly reorganized its library network to save money, but it neglected to justify its decision through appropriate cost-benefit analyses. Previous studies determined that the "benefit-to-cost ratio for EPA library services ranges between 2:1 and 5.7:1" (" Business Case for Information Services: EPA's Regional Libraries and Centers," EPA 260-R-04-001, January 2004, accessed Jan. 1, 2007 , at By rushing to close the libraries, valuable assets were disposed of at reduced rates; replacement costs for those assets if the libraries are reopened are likely to be greater than the original. Labor (straight and over-time), materials associated with the boxing and shipping of library materials, overhead (storage), shipping costs (sending library materials from closed libraries to others in the network or Cincinnati for digitization), consulting fees for conducting reports on the digitization process, and EPA administration costs resulting from the closings (time, report writing and testifying, replacements for materials that were needed immediately and could not be located in the boxes in time, and travel to scientific and library conferences to explain the closures, etc.) could make the process of closing the library more costly than the original $2 million budget shortfall.

Outreach: The Agency did not systematically consult with the full range of stakeholders, but is currently reaching out, "holding and attending stakeholder meetings and conferences." (Testimony by the other witnesses indicates that this outreach remains reluctant and primarily the result of repeated requests on the part of stakeholder groups and Congress.)

Future state strategy: EPA lacks an effective strategy to ensure continuity of library services following reorganization and its "phased approach … does not provide specific goals, timelines, or feedback mechanisms that allow the agency to measure performance and monitor user needs. …"5 The webpages associated with the EPA National Library Network ( are a significant improvement over what was available previously, articulating a vision and representing a system as opposed to individual libraries aligned with their own regions.

The director's testimony can be found at

EPA government employee concerns were represented by Charles Orzehoskie, president of American Federation of Government Employees Council 238. Grievances of Council 238 were recently sustained by a Federal Labor Relations Board Arbitrator. In his Feb. 15, 2008, ruling, George Edward Larney found that EPA acted "unilaterally without the benefit of employee input in closing or reducing access to seven of the agency's ten regional libraries. …"6 The library management now in place should learn from the past: saying that input is needed and welcome is not sufficient. Active outreach requires more "pull," in addition to the "push" exhibited through postings on a website, albeit a better website than in the past. Mr. Orzehoskie also outlined how reducing library access was hindering staff from doing their jobs and contradicts the agency's own mandated mission to protect human health and the environment as well as its contractual obligations with its staff.

The union had sought to reopen libraries that had been closed and to restore hours that had been cut in the remaining libraries. Unlike Congress, which in December 2007 ordered the agency to restore library services, the arbitrator admits that budget cuts make this an unrealistic outcome, though Congress did authorize $1 million for restoration of the library network. "In late March, EPA is supposed to report to Congress as to how and when it will implement this congressional mandate." We learned that the report is written and undergoing an internal review, primarily related to financing issues before being sent to the Office of Management and Budget (OMB). None of the stakeholder groups represented on the panel had been asked to review the draft report; the chair advised the witnesses to keep March 30–31 free, though their comments would likely not be incorporated into the report if EPA is to keep the Congressional timetable.

Orzehoskie spoke of the impact of the library closings beyond the union, on the public-at-large. Convenient access to older reports and technical documents has been reduced, and the promised digitization has not occurred. In fact, the 10% of unique library materials are not available yet, and no clear timeline for their digitization has been forthcoming. Even if the libraries are reopened, Orzehoskie doubts that there will be money available to replace professional research librarians at the libraries, "a critical aspect of any library." Orzehoskie's testimony can be found at

Francesca Grifo, director of the Scientific Integrity Program at the Union of Concerned Scientists, voiced the concerns of scientists regarding the library closures, particularly when it comes to accessing older EPA studies. She pointed to the lack of transparency in the decision-making process, faulting both the rapid pace in library closures and the slow pace of digitization. Efficiency and accuracy of EPA decisions are being called into question as a result of these actions. The lack of a clear plan and arbitrary deadlines were problems noted by the representative of the American Library Association, James Rettig, who followed Grifo as the committee's fourth witness.

Grifo pointed out how "the process by which EPA closed the libraries was backwards," with the physical libraries closing before the digitization process was complete. "Thousands of EPA documents are currently stranded in digitization limbo for the indefinite future."

A survey of 555 EPA scientists conducted in July 2007 reveals that the current replacement system is deemed "inadequate" ("InterLibrary Load service is an imperfect replacement") and the changes are "impairing" their ability to do their jobs. "Our survey indicates that the current system is not meeting the needs of hundreds of EPA scientists." Reduced library access is "crippling" to program offices. A few "immediate actions" were recommended and several "outstanding questions" can be found in Grifo's testimony at

Representing the library community at the hearing, Rettig (president-elect of the American Library Association) agreed with Grifo that lack of transparency in the process continues to plague the Agency. "From the library standpoint, the key issue to determine is whether or not the EPA's library plan is based on the end users' needs. We think not." Rettig addressed two issues during his testimony: "the vital importance of access to scientific, environmental, legal, and other government information for EPA employees, scientists and the American public" and "the necessity of the information specialist—the staff librarian—to ensure the most effective access to this information."

Rettig talked about the "convoluted and complicated" plan for dealing with library materials in closed EPA libraries, boxing them up and sending them to other locations to be re-cataloged or to Cincinnati to be digitized. He talked about standards that are used to create digital libraries, the importance of metadata, and digital asset management systems (DAMs). (While metadata is addressed in the "U.S. EPA Library Collections Digitization Process Report," Sept. 24, 2007, DAMs are not. The report can be found at Rettig's testimony can be found at

Molly A. O'Neill, assistant administrator for the Office of Environmental Information (OEI) and the EPA's chief information officer, reviewed the positive steps that EPA has taken in the past year, including hiring "a highly qualified professional librarian with many years of experience as the Network national program manager" to coordinate "all Network activities, providing strategic direction in all planning, operations, and outreach efforts."

The webpages associated with the EPA National Library Network ( display an array of mechanisms being used to present draft strategic plans and elicit comments (, update EPA National Library Network News (, and illustrate the network's collaboration with the Federal Library and Information Center Committee (FLICC).

O'Neill closed her testimony by pointing toward the agency's forthcoming report to Congress pertaining to EPA libraries requested in the Consolidated Appropriations Act of 2008. "EPA's report will describe the Agency's plans to ensure on-site support in each EPA Region, the EPA Headquarters Library, and the Office of Prevention, Pesticides, and Toxic Substances (OPPTS) Chemical Library." While the report is due by the end of this month, none of the witnesses had been given drafts so that they could submit comments in time for submission of the report to Congress. O'Neill's testimony can be found at'neill_testimony.pdf.

The webcast of the hearing is archived on the website for the Democratic Caucus, House Committee on Science ( A review of what led up to the closures, an update on the current situation with the libraries and the digitization of library materials, and an analysis of the revised library network strategy will be published in ONLINE ( once the agency's report to Congress has been released.


1 U.S. House of Representatives Committee on Science and Technology. 110 Congress, 2d session. (2008 March 13). Press Release: "GAO Report Finds EPA Library Closures Flawed." Retrieved March 13, 2008, from

2 Subcommittee on Investigations and Oversight of the House Science and Technology Committee. (2008 March 10). "Hearing on the Closure of EPA Libraries." Retrieved March 13, 2008, from

3 Subcommittee on Investigations and Oversight of the House Science and Technology Committee. (2008 March 13). "Opening Statement by Chairman Bart Gordon." Retrieved March 13, 2008, from

4 Subcommittee on Investigations and Oversight of the House Science and Technology Committee. (2008 March 13). "Opening Statement by Rep. Brad Miller." Retrieved March 13, 2008, from

5 U.S. Government Accountability Office. Testimony before the Subcommittee on Investigations and Oversight of the House Committee on Science and Technology. (2008 March 13). "EPA Needs to Follow Best Practices and Procedures When Reorganizing Its Library Network." Testimony of John B. Stephenson, Director, Natural Resources and Environment. Retrieved March 13, 2008, from

6 Public Employees for Environmental Responsibility. (2008 February 28). News Release: "EPA Library Closures Hampering Agency Work, Arbitrator Finds." Retrieved March 3, 2008, from

Barbie E. Keiser is an information resources management consultant located in the metropolitan Washington, D.C., area.

Email Barbie E. Keiser

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Comments Add A Comment
Posted By RICHARD WOLF3/17/2008 6:21:07 PM


If the library network had a hexagonal or roundtable matrix instead of a pyramidal heirarchy and sound financial support across the board (nationally) everything would work itself out.



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