The U.S. Environmental Protection Agency (EPA) was blasted in both judicial and congressional forums for closing seven of its libraries over the past several years. In a Feb. 15 ruling, a federal arbitrator found EPA guilty of unfair labor practices with respect to the closings. One month later, Congress heard testimony from several sources, including the Government Accountability Office (GAO), that EPA's library restructuring plan was poorly conceived, planned, and implemented.

Closed Libraries

Since 2004, six of the original 26 EPA libraries have been closed, one remains unstaffed, four others have reduced their hours, and one is scheduled to be consolidated in 2008. Looming budget cuts and apparent plans to digitize the agency's collections were catalysts for the reorganization. EPA began a series of studies in 2003 that evaluated the value of services and uses of the libraries, and in November 2005 created the Library Steering Committee, which was tasked with developing a plan for maintaining the quality of the library network on a restricted budget.

In anticipation of major Fiscal Year 2007 budget cuts, the committee's 2006 proposal included closing three libraries and reducing access to five others, in some cases by more than 50 percent. With no centralized management or plan for content preservation, libraries that were being closed or that were having their services reduced independently determined whether to digitize content, send it to other collections, or throw it away. Upon the request of Congress in 2007, EPA suspended further library closures, and the FY 2008 omnibus appropriations bill provided funding for the library system and directed the agency to come up with a concrete management and digitization plan that would restore library services. EPA's plan is expected toward the end March and may include reopening libraries.

GAO Report

The GAO, in its report EPA Needs to Ensure That Best Practices and Procedures Are Followed When Making Further Changes to Its Library Network, faults EPA with failing to follow through with many of its own initial recommendations, most importantly a comprehensive cost-benefit analysis and user survey, before starting the library closures. The staff survey that EPA conducted had a 14 percent response rate, which GAO determined was hardly sufficient to accurately ascertain user needs. Significantly, EPA also failed to gather information on public use of the agency libraries which, by EPA's own estimates, accounted for 20 to 40 percent of all reference requests. Additionally, the GAO found fault with EPA's limited efforts to evaluate alternatives to actual closures, such as reducing journal duplications, revising the outdated policy framework, or soliciting ideas from staff who know the libraries best.

The GAO concluded that as a result of these early missteps, the libraries' "reorganization" lacked agency-wide oversight, specific goals, and timelines for providing service continuity. EPA did not adequately assess resources for less disruptive, and potentially more efficient, transformation. EPA expected that digitizing information would reduce costs while maintaining access to the information. However, only ten percent of EPA's holdings are eligible for digitization since only EPA-produced reports are allowed to be electronically reproduced by the agency.

The lack of coordination and staff guidance has resulted in content dispersal and chaotic organization. For instance, all of the Chemical Library materials appear to be located at a library that has been closed for a full year. Additionally, many of the closed locations failed to develop any plans for replacing services that had been provided to the public.

Upon close investigation, GAO also found the budget crunch excuse circumspect. EPA has full discretion in determining libraries' funding, mainly determined by the Office of Environmental Information. The funding cuts appear to have been initiated by the agency before Congress passed its FY 2007 budget. EPA's actions may have actually made the library system less efficient by eliminating monies being brought in by the libraries. EPA's initial study found that between $2 to almost $6 came back to the agency for every dollar spent on the library system, largely aided by librarians' expertise with research. The agency's plans to replace actual librarians with computers or online services would severely reduce this source of compensation.

The congressional hearing included testimony from several other experts including:

• Charles Orzehoskie, president of American Federation of Government Employees Council 238, who spoke about the impact of the library closings on employees and the public at large. The Council was the union that filed grievances before the Federal Labor Relations Board Arbitrator.
• Francesca Grifo, director of the Scientific Integrity Program at the Union of Concerned Scientists (UCS), who testified about concerns of scientists and accessing important research materials. A UCS survey of 555 EPA scientists indicated that researchers found the reorganized system "inadequate" and that the changes are "impairing" their ability to do their jobs.
• James Rettig of the American Library Association stated that EPA failed to base its library plan on end users' needs. Rettig also addressed the importance of "the information specialist — the staff librarian — to ensure the most effective access to this information."
• Molly O'Neill, assistant administrator for the Office of Environmental Information (OEI) and the EPA's chief information officer, defended the agency, claiming that many positive steps had been taken, including the hiring of a chief librarian to provide strategic direction to the agency's plans. O'Neill also noted that EPA would soon be releasing a report to Congress to describe the agency's plans for the EPA library network.

EPA Guilty of Unfair Labor Practices

In a recent ruling, Federal Labor Relations Board Arbitrator George Larney sustained complaints by the American Federation of Government Employees Council 238 that EPA acted "unilaterally without the benefit of" employee input in regard to the library closures. Though the agency has claimed to prioritize EPA staff access to information (while virtually ignoring the public's), Larney heard the opposite from EPA scientists, enforcement agents, and other staff.

Larney ordered EPA "to engage the Union in impact and implementation bargaining in a timely manner" before taking any additional steps to reorganize the library network. The union had sought to have the closed libraries reopened, but the arbitrator declined such an order and noted that it would impossible for EPA to reopen those libraries that had been physically dismantled.