Tuesday, March 18, 2008

Another system that worked, destroyed by the Bush administration

Most of the authors who post to this blog can fairly be categorized as good-government Democrats. We took a shine to that government we learned about in ninth grade civics, and have spent the intervening years telling anyone who would listen that we really ought to give it a whirl.

Being good-government Democrats, we have been horrified as agency after agency that serves the public good has been gutted and parceled out under this administration. The GAO, the DoJ, the CDC...

One of those things that worked that fell prey to this administration was the EPA library system. (The EPA laboratory system has been decimated, too, but that will be another post.) The facilities started shutting down a couple of years ago, but not a lot of notice was paid to it - scientists protested, but we are a tiny fraction of the population and we are in hostile territory with this anti-science administration any way. We don't get a lot of love from these folks, but we don't sit up at night crying about it, either. We do sit up crying at night over the closing of scientific libraries that provide information and educational services to researchers, academicians and the public at large.

Now the GAO is advising that the EPA slow down on their restructuring activities and make sure that they are employing best practices and procedures when making changes to the library network.

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.
Currently, the libraries remaining in the network answer to a variety of different offices. Each office makes general decisions about funding allocations and funding the reorganization activities. When a $2 million budget shortfall was handed down in FY 2007, the EPA specifically directed that the libraries absorb the cuts first, but they did not offer any guidelines or protocols for achieving the reductions. The rationale for the shutdowns and restructuring was cost savings, and no shut-down fees were allocated. The libraries were targeted in spite of being found cost efficient in a 2004 audit, and in spite of providing a unique and important public service. The GAO found that the "EPA did not effectively justify its decision to reorganize the library network because it did not implement a process for conducting a number of analyses, including many that were recommended in its own study of the libraries, prior to initiating the reorganization." (PAGE 4)

The GAO also found that the EPA not only failed to follow best practices, but they also failed to follow regulations from the OMB. (PAGE 5)
Office of Management and Budget guidance recommends that agencies conduct a benefit-cost analysis to support decisions to initiate, renew, or expand programs or projects, and that, in conducting such an analysis, tangible and intangible benefits and costs be identified, assessed, and reported. However, EPA did not perform a benefit-cost analysis in this case. According to EPA officials, OEI decided to reorganize its libraries without completing the recommended analyses because it wanted to reduce its fiscal year 2007 funding by $2 million to create the savings necessary for its headquarters library and the regional office libraries per
the President’s budget proposal.
Nor were stakeholders informed of the consequences of the restructuring, and communications strategies were inconsistent and slap-dash, failing to inform affected personnel both internal and external how the proposed changes and closures would affect them and what strategies could be employed to assure that access to vital research materials remain available to scientists and the general public alike. They also failed to solicit feedback, another box on the checklist that is supposed to keep silly things like closing down libraries willy-nilly from happening in the first place.

Now, after the fact, they are reaching out to stakeholders, now that the damage is done, so to speak. But they are reaching out without an effective strategy to ensure the continuity of library services, and without having a clear idea of how the restructuring has affected the availability of library services.

The GAO also found that the EPA did not follow standard protocols (best practices) that are designed assist organizations during mergers and restructuring, but things as basic as feedback from staff were not employed, instead the restructuring seemed to be top-down and somewhat arbitrary. The EPA describes it's library plan as "phased approach" but it has no goals, timelines or evaluation mechanisms in place. The criteria offered by the EPA has been vague and the guidance and oversight has been relatively non-existent.

The GAO recommends that the EPA continue the current moratorium on further changes to the library system while the system as it exists today is fully assessed and a plan for completing the restructuring is developed and a plan for implementation in place.