March
4, 2002
Ms. Kim T. Nelson
Assistant Administrator
Office of Environmental Information
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
MC 2810A
Washington, DC 20460
Dear Ms. Nelson:
The purpose of this letter is to encourage the Agency to take steps
to improve the utility of the data available on the environmental
performance of industrial facilities. As you know, environmental
information plays an essential role in advancing EPA's objectives
of protecting public health and the environment.
In light of the importance of environmental information, we believe
that EPA should explore several steps to enhance the practical utility
of the information available to the public by establishing a single
facility identification number, setting up an integrated system
for reporting and access of data across multiple programs, and improving
the timeliness of the availability of Toxic Release Inventory (TRI)
data. In undertaking such steps, EPA will be advancing the goal
-- identified by Congress in the 2001 Appropriations Act (Public
Law 106-554; H.R. 5658, section 515(a)), and detailed in OMB's recently
issued Information Quality Guidelines -- of ensuring and maximizing
the quality, objectivity, utility, and integrity of information
disseminated by Federal agencies.
The adoption of a single facility identification number for reporting
facilities has long been recognized as an important step in making
data readily available to regulators and the public. This effort
will augment the practical utility of the data by making it easier
for the Agency, other governmental entities and the public to link
data reported by a facility in different contexts (e.g., TRI data
and water discharge data). In 1995, EPA began work on a rulemaking
to establish common facility identification information across all
its information collection requirements; more recently, however,
EPA has channeled its efforts toward the development of the Facility
Registry System. We encourage EPA to place a priority on the completion
of the effort to create a unique facility identification number.
Second, the adoption of a single entry data system will improve
data quality, provide a comprehensive data set for each facility
for use by EPA, State, and the public, and eliminate duplicative
reporting requirements and the associated burden on regulated facilities
of making multiple submissions of essentially similar data across
EPA's programs. We understand that the development of the central
data exchange (CDX) will provide for the gradual integration of
existing databases into a single data repository and will eventually
realize the goal of providing a single data entry system. We recognize
that creating single data entry represents a significant undertaking
that will require a coordinated agency-wide effort. The creation
of a unified Office of Environmental Information to coordinate data
collection, management, and dissemination throughout the Agency
was an important first step. We encourage the Agency to develop
a strategy to integrate databases as they are brought into the CDX
and to move to a single data entry system as expeditiously as possible.
Finally, EPA should explore ways to expedite the release of TRI
data. Under EPCRA, industry respondents report their releases for
the reporting year on July 1 of the following year. However, there
has been a considerable lag in recent years in the public release
of this data. For example, we understand EPA plans to release the
TRI data for 2000 this Spring -- almost a year after it was received
and more than a year after the end of the reporting year.
Under our regulations implementing the PRA [§1320.3(e)], one
of the measures of the practical utility of a data collection is
the timeliness with which data is available to the collecting agency,
to other government entities, and to the public. In order to improve
the timeliness of the release of TRI data, we encourage the agency
to explore ways to expedite the processing of the TRI data in order
to achieve an earlier release. One way of doing so is to encourage
greater use by respondents of electronic reporting. The increased
use of electronic reporting reduces the transcription and quality
control burden on the Agency and should allow quicker processing
of the data.
In processing the TRI data, the Agency also conducts a careful quality
analysis of the data to identify potential errors in facility reports
of releases or transcription of facility reports. For example, EPA
compares the reported data with release data from earlier years
to identify "anomalous" or "outlier" reports and follows up with
the respondent in an effort to identify errors in reporting. In
conducting this analysis, EPA is assuming some of the quality assurance
burden that properly rests with the respondent. Respondents should
be responsible for the quality of the reported data. Of course,
EPA remains responsible for errors that occur during its own processing
and analysis of the data and should continue to ensure that these
are minimized. We encourage EPA to review its quality assurance
role in order to reduce the processing time for TRI data and allow
an earlier release of the data to the public.
In conclusion,
OIRA recognizes that EPA has limited staff and budgetary resources
to implement a large number of statutory programs. We look forward
to discussing this issue with you soon, and would appreciate a response
to this letter within 60 days. As always, my staff stands ready
to assist you in this effort.
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Sincerely,
/s/
John D. Graham
Administrator
Office of Information and Regulatory Affairs |
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