EPA Background Document

The American Society for Environmental History has passed a resolution opposing the closure of Environmental Protection Agency libraries.

The Environmental Protection Agency has begun closing substantial portions of its network of technical libraries—the largest collection of environmental materials in the world. In October 2006, without notice to either the public or affected scientists, the EPA closed the Office of Prevention, Pollution and Toxic Substances Library, its only specialized library for research on the health effects of toxic chemicals. Major regional libraries, including those in Chicago, Dallas, and Kansas City, have also been closed this fall, with more closures expected.

The EPA libraries contain a combined collection of 504,000 books and reports, 3,500 journals, 25,000 maps and 3.5 million information objects on microfilm. These libraries receive more than 134,000 research requests a year from EPA staff, in addition to requests from the public. Losing access to these records will impair the research of environmental historians as well as the work of EPA scientists and enforcement specialists. EPA Administrator Stephen Johnson states that many library materials will be made available electronically, but this is no substitute for public access to the current collections.

Virtually none of the EPA records that exist prior to 1990 have been digitized. These historic records are critical for understanding environmental conditions. Trying to piece together responsibility for PCB contamination at a Superfund site, for example, would be impossible without such records. For communities of color struggling to understand asthma and air contamination, for epidemiologists searching for patterns of mercury deposition and disease incidence, for historians seeking to learn about restoration of streams after the Clean Water Act—the holdings of the EPA libraries are quite simply irreplaceable.

Under current EPA library plans, thousands of unique holdings will be inaccessible for an undisclosed period. While EPA staff have stated that “unique, EPA-generated” documents will be digitized within the next two years and made available online, these account for less than 1% of the holdings of the EPA libraries. No plans currently exist for digitizing records from before 1990. No plans appear to exist for cataloging materials before storage, or for sending dispersed documents to Federal Records Centers where public access can be assured. The EPA library plan does not allow for continued public access to EPA libraries; the only public access to EPA documents appears to be to the small fraction of the collection that will be digitized. These factors make us concerned that many important records will be inaccessible, perhaps indefinately.

EPA staff have argued that these closures are justified because visits to the libraries have declined. While this may be the case, many government services are not used daily, but that doesn't make them any less valuable when it is time to use them. When the funds and competence associated with any such government services are cut, we have seen the dire consequences that can follow. The retention of historical memory--the archiving of knowledge and documents that would otherwise be lost forever--is among the defining attributes of civilized community. Not everything should have to pass a cost-benefit test to be protected.

The full text of the ASEH resolution can be found here.