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Information Impacts Committee

National Advisory Council for Environmental Policy & Technology

Information Impacts Committee

September 10 - 11, 1996

Meeting Minutes

Meeting Site: Dupont Plaza Hotel, Dupont Circle, Washington, D.C.

September 10, 1996:

Attendees: Patricia Bauman, The Bauman Foundation

Patricia Cummens, New Jersey DEP

Jack Dangermond, Environmental Systems Research Institute

Tom Davis, Tom Davis & Associates

Suzanne Hess, Hunterdon County, New Jersey

Patricia Hill, Georgia-Pacific Corp.

Michael Moilanen, Mille Lacs Band of Ojibwe Indians

Cheryl Morton, Synthetic Organic Chemical Manufacturers Assn.

Julie Norman, Headwaters

Paul Orum, Community Right-To-Know

Joe Sierra, DFO, U.S. EPA

Mark Day, OIRM, U.S. EPA

• The IIC Chair, Tom Davis, and the DFO, Joe Sierra, officially opened the meeting at 8:30 A.M., September 10, 1996. Mr. Davis reviewed the Agenda (Attachment (1)) with the members, and it was approved by the full committee.

• The Committee Chair indicated that a major committee focus for the next two days would be the development of a set of interim recommendations that would be forwarded to EPA, as a result of the information gathering efforts the committee had been undergoing since the first meeting in April, 1996.

• The Industry Panel was introduced and asked to make their opening statements. Key points from these statements included the following:

• Frank Gorski, Environmental Health and Safety Manager, Huntsman Polypropylene Plant, Woodbury, New Jersey

• Huntsman is one of 17 companies in the State of New Jersey that has volunteered to participate in one of New Jersey's approaches to new partnerships. This effort is a facility-wide, multi-media permitting program.

• Huntsman is considered a medium size chemical company. We sit on about 70 acres of land; have about 200 employees; and work 24 hours a day, 7 days a week, 365 days a year. Polypropylene (a general purpose commodity plastic with thousands of uses) is our only product. We do not make consumer products. We make the plastic and sell it to a molder.

• Huntsman has developed a third generation catalyst that can now be used in a slurry process and can compete with new gas-phase processes. Huntsman has committed $25 million to modernizing and retrofitting the Woodbury Polypropylene Plant. Based on that decision, we volunteered to participate in the facility-wide permitting process.

• New Jersey's regulators are not nasty to work with, but they are difficult. They're very bureaucratic and have a very strong enforcement mentality, so it takes a lot of commitment to go into the State of New Jersey and be willing to work through this process with them. New Jersey's basis for a facility-wide permit in New Jersey comes from the state's pollution prevention regulations. Companies are required to have a pollution prevention plan (a five year plan of pollution prevention goals, in the true sense of what New Jersey calls "non-product output.") It includes all phases of pollution prevention, so a multi-media permit is developed that brings in all phases of air, water, solid waste into one permitting process.

• Because the plant was going to be rebuilt to accommodate modernization of the catalyst, approximately 80 air pollution stacks and 300 sources ranging from new permits to grandfathered sources were going to be required. One prior permit renewal took 2 ½ years, and the state would not approve a compressor, which cost us an 18 month delay and $3.5 Million. With the 80 stacks and 300 sources being affected by modernization and needing to be re-permitted, we needed a streamlined regulatory process. It was critical for New Jersey to work with us to do this in a process manner, versus an individual point-by-point, source-by-source permit.

• Allen White, The Tellus Institute, Boston, MA

• Tellus is a non-profit research and consultant group that works with EPA, business, foundations, etc., on programs such as Design for The Environment, environmental accounting, and initiatives such as CSI.

• We recently completed an in-depth survey of 5 companies in New Jersey that have been through the New Jersey pollution planning process. We were part of an evaluation team that reviewed how the process was functioning, what went right, what went wrong and what can be improved. New Jersey's planning process is probably one of the more demanding and complex processes in the country.

• Over the years, information systems and business (from an environmental context) have developed certain trends:

• Information demands for meeting reporting requirements and disclosure requirements have expanded steadily, and aggressively, for the last 20 years.

• Expansion has been piecemeal. One information requirement has been layered on the other without much connection to those below it or those that come after it.

• The demands have been media or medium linked, rather than holistic or integrated.

• The demands have been linked to outputs, not inputs (what comes out the stack or pipe, rather than what comes into the factory gates and through the process.)

• As we look today at what business is saying to us, there are a few characteristics we can use to describe environmental information systems, as they currently operate:

• Environmental information systems are unyielding.

• Their landscapes are chaotic and uncoordinated. There may be, literally, dozens and dozens of permits at one site, with one, having little to do with another.

• Use and interpretation of the information is problematic, within the factory gates as well as outside. The fault lies with the companies who often don't actually grasp, or have in some organized fashion, all their various data sources so that they can use them coherently and efficiently. Fault also lies with the user community outside the gates. They try to make sense and ask simple questions, like, "How is this facility doing? How is it progressing towards, say, a pollution prevention objective? How is it progressing toward a commitment to reduce VOC's by 80 percent, or 60 percent, or something like that?"

• So the larger question becomes: Is there common ground between those who generate information (businesses), and those who use it? Are there problems that are shared to point where we can proceed and ask questions about information management where solutions can be joint and mutually beneficial. Generally, I think the answer is yes. Too much attention is focused on where there are differences, and too little attention focused on whether there are commonalities and shared interests in getting the information. Businesses' objectives regarding better environmental information are fairly straightforward. Every day business makes decisions. Every intelligent business manager wants to maximize resource productivity and ensure its long term competitiveness of the facility.

• How do I measure progress toward objectives or goals? How do I price products going out the door? What's the right price? Environmental information can assist in making an informed decision. How do I set up intelligent rewards and incentives so I'm getting the most out of my employees, workers, managers? Can I link those to certain forms of environmental performance? How do I benchmark my performance against my colleagues down the road... benchmarking in terms of my own environmental achievements? Those are kinds of decisions that environmental information can and should, but often doesn't, inform.

• On the regulatory side, there are regulators that, in the wake of the President's Council on Sustainable Development, would say that we're not only interested in regulating, keeping the air clean and the water clean, but interested in competitiveness, as well. The environment should be linked to competitiveness. We are stewards of natural resources. Productivity at the plant site is integral to productivity and efficiency and intelligent resource management at the national level. So it's in our interest, and our country's environmental interest, to have firms operate in a resource productive fashion. We certainly are concerned about progress measurement. We want to know how our pollution prevention policy is working. So does business. Progress measurement is a shared goal and objective in use of environmental information.

• Communities should be interested in resource productivity within the gates of a local factory because that's going to ultimately determine whether the factory's going to be there in 10 years. When communities ask a company how it's doing, part of the answer should focus on how you're doing in terms of efficiency. "Are you extracting value out of that product, out of those materials that are coming in the door and going out as a product?" It is in the interest of communities that firms be efficient. It's partly environmental, and partly job retention and job security. And certainly, communities want to know about progress measurement....are companies living up to their goals, meeting their targets, and generally working toward higher levels of environmental achievement and excellence?

• Communities also have a strong interest in benchmarking. If they have a chemical plant as a neighbor, they should know, and they deserve to know, whether that facility is operating, at a minimum, at the industry standard. That is a form of benchmarking.

• Mark Greenwood, Robes & Grey , and Coalition for Effective Environmental Information (CEEI)

• CEEI is a coalition of companies and of trade associations that have come together around common issues about environmental information. Membership goes from oil and paper and chemicals to electronics and a lot of other fields as well. They are very united in saying that the environmental information, and how it is collected, used, and disseminated, is going to become a critical issue in environmental protection. The coalition is certainly united in the notion that improvements in this system are necessary and can serve everybody's interests.

• There are general goals of public policy, and certainly the public's interest in Right To Know, that the coalition is very much committed to working with EPA and other government agencies to support. It is interested in having an information resource base developed that really answers the right questions, is accurate, is maintained up-to-date, fair to stakeholders and tries to link information to relevant and important environmental values and health and environmental values.

• One of the most fundamental issues and recommendations we make to this committee is: There needs to be a more holistic approach to environmental information at a place like EPA. It is our belief that the current system in environmental management and in environmental information really doesn't serve any of the stakeholders particularly well. At the outset, it's a very large enterprise. EPA now estimates its spending something like $300 Million a year on information management. Its calling for reporting of record keeping burdens at about 100 Million burden hours, and it is now providing information in all kinds of different ways. Things like TRI are obviously very well known, but Internet, and other tools are evolving.

• We think the core problem is the fact that EPA does not think of information management as one program, rather as set of series of individual initiatives which are not linked. Because of this, there have been failings in the process, including:

• Information often comes in without a clear purpose, a clear audience, and/or often has significant overlap and duplication.

• A lack of common definitions to allow comparisons between one data set and another.

• The right questions are not always addressed or answered.

• The sense that there is an uneven quality of the data as it comes in, and is used, in the Agency.

• A sense that some of the scientific underpinnings are not always up to date.

• Fundamentally, no clear ground rules for participation and development of [information] resources, nor what fair play means in the development of these resources.

• In fairness to EPA, they have developed an IRM strategic plan which we think has some very interesting ideas. EPA is recognizing that it needs to have a more holistic approach, but we're at a point where we need a more developed action plan. EPA needs to start thinking of environmental management as one program. It needs to be a single program culture (maybe a virtual program.) There has to be a common set of goals, as well as a common set of strategies and processes for how an environmental enterprise is going to operate.

• A second critical point is that stakeholders need to have clear ground rules for participation. Increasingly, everybody is aware of the power of information in the marketplace. Information can be more powerful than command-and-control regulations. An example of this is the tax release inventory (based on the premise that one could influence, prior to behavior, through information.) Also, the facility sector indexing project is an example within the enforcement community, where compliance information is placed in public domain as a way of influencing behavior. It is a trend that EPA recognizes, but that needs ground rules. If these kind of changes in behavior were to be done through command-and-control regulation, there would then be very clear ground rules about how one participates.

• There's also the issue of how you protect against misuse of information. If a third party is to misuse information that EPA puts out, whose concern is that in the government? Is that something that EPA should worry about?

• EPA needs to recognize that the business community is a stakeholder in all of this. Business is both an information user and submitter. CEEI, as a group, certainly supports the notion of right-to-know, in part because the business community is a user of information that EPA may have. But there's a feeling in CEEI members that the current system doesn't particularly serve the use of that information. The "Right To Know Better" is really the right that should be developed, and that does not always mean the "Right To Know More". But it might mean better use of information that already exists, and providing a more useful and more understandable way. That should be a focus of any development of resources.

• There is a sense from the business community that what is really needed is more contextual information. What is the significance, for example, of a TRI release? Where does it fit? Is it important? Is it significant? What is the context to give people some understanding? The current system has a tendency to dump data...not necessarily to enhance understanding. For example, what does TRI data about releases and chemicals and waste really mean in terms of risk, and what is important in this sea of information now being placed on EPA's Internet home page?

• Ultimately, business needs confidence in the information that is going to be getting from EPA, or any other resource. Is it high quality information? Is it up-to-date? It may be that some companies will make investment and disinvestment decisions on that information. They must have some confidence in the quality. There's a lot of reliance in the business community on government information resources. There needs to be a commitment to quality to make sure that reliance is well-taken. One of the greatest fears that the business community has is that there's not enough evidence right now that EPA is investing in the quality of information and making sure that it's scientifically up-to-date.

• Belinda Townsend, The Boeing Corporation, and Coalition for Effective Environmental Information (CEEI)

• Information can be a little unyielding and overwhelming if you don't get a grasp of it. In the environmental arena, my organization is very similarly structured to EPA. We are divided by media, so getting a comprehensive feel for our reporting requirements was very difficult. Different pieces of information were contained in different parts of the organization. We had to step back from the current reporting process to look at it, as a whole. We needed a holistic process in order to comply with our reporting requirements. Because our process was media-specific, we didn't really know what our total requirements would be. In performing our review, we found:

• In the course of one year, we spend 23K man hours to complete 70 reports which are submitted to five different offices in EPA.

• This process cost us $1.5 million a year.

• The money spent to gather the data was not an issue (we realized that gathering information is very important.) What bothered us was the 23K man hours that it took to comply with the particular requirements. So we stepped back (in the interest of being competitive and the fact that we needed to find a way to make this more efficient) and decided there had to be a way of improving the process. In our review, we found that we ran into not only our own internal road blocks (which we could fix), but some road blocks that were a part of just the legal requirements. For example, we found that we had the same reporting requirements for some chemicals, 8 different times.

• We found several things preventing us from consolidating reporting requirements:

• All our identification numbers, by media, are different. No facility identification number was the same. From a layman's point of view, trying to find out what's going on at a facility is a very cumbersome thing to do.

• Measurement units vary between media and reports. For Air, it was Tons. For RCRA, it was Pounds. For , Water, it was Parts-Per-Million/Billion. Every unit of measurement was different.

• Thresholds and deadlines were different.

• So, what can be done? Our recommendation, as CEEI, is that we step back and look at a comprehensive, integrated, program and system. When these programs were first developed, they were developed on a media-by-media basis. This committee has an opportunity to step back and ask, "What is the information that EPA, not each media, needs?" And to provide a framework for them to do this efficiently. Hence, an integrated system with environmental information that represents basic principles. If we're going to gather information, what are going to be the principles that guide us in developing this information? We've submitted principles from CEEI and have given to them to Joe to be submitted for the record (Attachment (2).)

• Rex Tingle, Industrial Hygiene Environmental Health Labor Representative, AFL-CIO

• I'm here to talk to you today representing over 14 Million potential users of information. The first thing I'd like to say is that the AFL-CIO supports regulatory flexibility. We would like to see simpler, easier information (100 Million burden hours is a little high), and we encourage the EPA to make sure that when looking at regulatory flexibility they don't allow the omission of information that we consider necessary for workers and communities to protect themselves. We (AFL-CIO) would be very happy to sit down with government and industry to try and define what is deemed necessary information.

• The second issue I'd like to identify is CBI. In order for any of this information to make any sense for the user community (i.e. environmental community, the worker community, and the environmental justice community), the CBI issue has to be addressed and there has to be some type of CBI reform. When we talk about regulatory flexibility and the type of information, we need to take a holistic approach and make sure that we do have some useful information that users can actually make use of. Labor is also part of the stakeholder group. As I mentioned before, we are 14 Million potential users (and that number does not include family members or the environmental justice community.)

• One of the major issues I've been struggling with for the last three years is trying to bring environmental issues to the forefront of the labor movement. It is a tertiary issue to them, but we're working to alleviate this problem. So it's very important that you develop information that these people can actually use. They won't look at the tonnage of information released. They're not going to look at certain other issues that everyone at this table may look at. We have to make sure that we're putting out information that's in a format that they can actually interpret so they're not as overwhelmed by it. It has to be information such as occupational exposure demographics.

• Regarding information access: We have been trying to train all of our people on the use of Internet (and trying to train 14 Million people is hard), and we would like to make sure that EPA has 24 access to its data (whether via computer, phone, etc.) We'd also like to see a "1-800" user hotline, so people who are computer illiterate can call in a get some help and get walked through. Other things include tools like "YAHOO" on the Net, and technical representatives that could act as advisors to users.

• We have been very happy to see that the Agency moving towards the key identifier project. We think that project is moving in the right direction.

• We would like to see the Agency implement a customer service committee that takes a look at all the complaints, good things, indifferent things, and new information that's out there, because new information is going to be out there on a more regular basis, and we'd like to make sure that we keep moving forward.

• We would like to see information such as occupational exposure demographics; information on chemical use; and chemical flow information. All those types of information are going to be very useful for the large number of users out there. And it's very important that this information be put in a format that is very user friendly and very understandable for the people who are using it.

• At this point the Panel Session was opened to questions and dialog. Key issues and points raised during this session included the following:

• Mr. Davis: What steps has the CEEI taken to get your message to EPA?

• Mr. Greenwood: First of all, we [the CEEI] have been together since May, so we're just starting. We have been talking to several people in the Agency. We have a Statement of Purpose document which we put together which lays out a general agenda. And we are going to be talking to several folks this fall. We have been interacting with some of the groups at EPA that we think are trying to do things rights. We're looking more systematically at OSW's information requirements, and we've been working with them to get a sense of how they're approaching information management, and so on. And then we'll be commenting on things as they come along. The difficulty right now is that there isn't one place that has a handle on everything. EPA just recently identified a Chief Information Officer, and we've talked to him a little bit. Perhaps that will be the point of entry, but that is frankly a challenge for us. And we're trying to deliver a message about a broader need to find a place where you can interact.

• Mr. Dangermond: Frank [Gorski], you talked about all the problems that you're having, and all the different permits you need, but you didn't actually talk about the multi-media permit process. You fell short of commenting about what your thoughts were on that. Was that something that was really working for you, or not? Was it just more of the same?

• Mr. Gorski: It is, and it's not. It's new. The permit has been in place since January of 1996, so it's only been in effect for six months. The exciting part of the permit is that it is structured as one multi-media permit. It's also structured by process, not by source. One of the exciting parts of the permit was the community interaction as we went through the permitting process. The process itself took us over a year, because there are no application forms and no standard way to do it. The bad side is that we're reporting both ways. We're also doing it under the old system. Our emissions report runs 72 pages. We just submitted our first report under the facility wide system, and it ran three pages. Nobody's going to read or understand the 72-page report that we submitted...nobody but the technical people. Everybody can generally understand the three-page report that was submitted. It has a lot more benefit. My guess is even the Agency New Jersey DEP will only take the summary sheet of the 72-page report and use the three pages.

• Mr. Orum: What's on the three pages?

• Mr. Gorski: We have about 300 sources, 80 stacks, and 4 discharge points, all on an emission statement. Every one of those show up individually, and individual data is broken down. It's the same numbers, divided by 300 in hours of operation, and worked out on the large report. The three-page report is a process. We broke the plant down into four processes. So we report four process emission (four process sets of data for air total, multi-media emissions to air, to water, and waste) in one holistic number.

• Mr. Dangermond: Why are you still doing two reports?

• Mr. Gorski: The new report is voluntary. There's no place to submit the new data. The New Jersey Information System can't handle the new data. All the stacks have different numbers. The old system has stack and process numbers. The new permits were assigned all new numbers. They don't mesh. They're in a whole different format. That's probably the most difficult part. I don't get multi-media inspectors. I still get a single-media inspectors who wants to see their piece. And, not only do I have a new system and an old system, I have an index system to show the inspector how the old system integrates into the new system so he can now come out and inspect.

• Mr. Tingle: Frank touched on a very important point that we found over the course of the CSI process and in the President's Council for Sustainable Development: Community outreach is a must, not just for EPA, but for industry, organized labor, environmental justice, etc. We actually have to go out and help educate the consumers who are out there looking at this information, because we run into this problem all the time, not just with EPA related issues, but in our OSHA related issues as well. People get information and they actually don't understand if something is good or bad. They just see a large number and start to panic. And, that's a part that I think all of us in this room get an "F" in, because we have not educated our members or our constituents the way that we should have.

• Ms. Bauman: I wanted to say something in response to a point that Mark made about the power of information to shape behavior: Recognize that information is not a substitute for regulation. There really is a role for both. Secondly, you [Frank Gorski] are subject to a lot of statutory regimes, part of the patch work, duplication, overlap, lack of standardization, and so forth, that comes from the way that the environmental laws have accredited, if I can put it that way, over time. So, I think the watch word that I've heard, and it's one that I certainly share, is the need for data integration. I think the key identifier is help, a one-stop shopping, a point of responsibility within the Agency. I'd like to hear this from both Allen and Frank. My question to any of you is, what are the concrete steps that a committee such as this might recommend in order to foster data integration?

• Mr. White: Well, that's a tough one. The statutory and regulatory legacy here is very problematic. I've seen any number of firms, firms that are smart, big, and sophisticated, that have their own databases set up to respond to Clean Air Act, Clean Water Act, NPDS permits, etc. (the usual array of disjointed databases.) I seem them continue, almost trapped, shackled by the requirements that they face month to month and year to year to provide TRI information here, and to provide water quality information there. Almost, paralyzed by the amount of information they have, in-house, and worrying about meeting the next compliance date, and asking, "What information can we link to facilitate our own internal decision-making?" Just two weeks ago, I came across a company that had an amazingly rich database of chemical information that, almost literally, with five hours of a computer programmer (which this company could well afford) could make for itself a wonderful process flow information system by linking chemicals to processes at a very dis-aggregated level. In other words, the raw material was all there, but the architect wasn't. And, therefore, the data continued it's routine, grind it out, next compliance report function. And the opportunities for informing their internal business decision-making or streamlining, for looking at process flows, and for understanding resource efficiency aspects of their business (generally making it all work better), they had not taken advantage of. There are untapped opportunities, unexploited by firms, for making better use of the information. To your point, what I might recommend is, demonstrate some successful models of industry firms or facilities taking charge of their existing information resources and saying, "Look, here's five things I did. I'm going to stop complaining now. Okay. Here's five things I did with the information resources as I now have them. I'm going to show what I did. I linked this permit with that permit. I did this with that and so on, and I came out of it a smarter company." That could provide an empirical basis, a real world application, a foundation.

• Mr. Greenwood: I think you have to work back from what you think the barriers are. As you mentioned, the laws do create somewhat of a barrier. Also, they're really the institutional obstacles within the Agency. The Agency is set up on media lines, as separate programs. One of the things I've heard from EPA staff is that they like the idea of integration of data, but they don't have a sense of trust across the program that an information piece that they want will stay there tomorrow if they don't have it in their own program. So they duplicate information they know is elsewhere, because they're just not sure that other programs will really keep it in place for their use. So, you have the laws. You also have the institutional obstacles and the lack of trust in the system. There are two things the Agency can do to try to deal with that: One is to take stock of what you now have. What are you now getting? What are the opportunities for integration? And what are the real legal obstacles? My own perception (after many years in the Office of General Counsel to EPA) is that there are often fewer true legal obstacles, than people sometimes assume at the beginning. Most of these statutes have not said a lot directly about information, per se. They talk about what is a source or facility, and sometimes these are the things that complicate the information comparisons. But I think there are probably some opportunities to integrate information under the current laws that can be explored. And I would think the Congress is probably going be much more receptive to looking to those kind of problems when they arise. The second is to commit to an integrated system. Make that an objective of policy at the Agency. That will start to build the linkages across the programs, start to build the atmosphere of trust that would allow a more integrated system to be developed.

• Mr. Gorski: Committing to an integrated system is absolutely the first way to get there. I am also in total agreement on how big a barrier compliance is. There is a very strong self-serving interest in not breaking down barriers. People want, within their own agencies and programs, the information in their own format. So I think committing to an integrated system is extremely important to get all of the individual medias focused in the same direction to break down their institutional barriers. Also, we all have the same data, if you want to stop and tell us how to put it into one format. The data is out there to do that.

• Mr. Orum: I think I understand pretty well the incentives and needs laid out around permitting and monitoring. But I'm very skeptical about what EPA should doing, agency-wide, at present. There are very strong incentives that may not play out, but if the Agency, or New Jersey, or someone, does look across all permits, they're going to find emissions that are un-permitted. Also, there are very strong political incentives not to come out with reports that show big blanks on your map, because then the implication is that you need that information, and you need to have a regulation to cover that. I think there are a lot of barriers, therefore, that could come up. I also think that these pilots offer a very limited approach. I think maybe we do know enough to suggest certain things agency-wide. What can EPA really do that will move forward at a much quicker pace and a larger level? What are the concrete steps at that level?

• Mr. Gorski: I don't have a straight response. Just within the State of New Jersey, to make things happen quicker takes, a more significant commitment of the DEP. As we went through the permitting process, every time we ran into an institutional barrier, we went to Steve Anderson who managed the program. Steve had to go to his equivalent in the air, his equivalent in waste, and at that level, (middle to upper management), they were able to be creative. They were able to resolve the issue. The individual permit writer who you originally deal with, who has his guidelines and his formals to work with, and less flexibility, can't make those decisions. That's a significant management change, at least at the state agency, to be able to do that. A tremendous barrier in facility-wide permitting is the training for the enforcement officers. A guy whose been doing water pollution for 10 years may be a terrific water pollution enforcement officer, but is now being asked to do air and RCRA inspections. He has to learn those regs, understand the whole process. Being a volunteer facility, we had one chemical engineer who, today, knows my polypropylene process as well as I do. He can tell you how a molecule of propylene comes in our plant, and how it leaves as polypropylene. What do we have, 10,000 plants in New Jersey? How do you get that level of expertise to help through that system? That's a tremendous management problem to integrate and to bring down to lower level managers and permit writers. .

• Mr. White: To reinforce what Frank said, there is a disconnect between the direction of voluntary programs at EPA and the direction of the on-the-ground, grind-it-out, permit people. What you hear at EPA these days is sector and industry approaches. Everything is designed for the environment as sector or industry-based. There are various initiatives around cluster rules for pulp, wood, and paper industries. That seems sensible, but on the ground you have the same old guys writing the air permit, and someone else writing the water permit, etc. If you're going to drive home the message of integrated facility management, cross-media permitting, holistic data management and data requirements, you've got to bite the bullet and say, "Okay, the people who are at the enforcement, inspection, or the permitting levels, you have to be responsible for a set of facilities, not for water, for air, for waste, but for this cluster of facilities." And if that cluster were organized around a sector like the pulp and paper sectors, you wouldn't need one person. You'd need, maybe, 10. But the learning's got to start somewhere. The problem is one of learning. You have people who understand what it takes to write an air permit, because they've been doing it 10 years. They know every detail, every minute point in writing an air permit. You're giving him a new job description. And you say, "You're not only going to know about air, but you're also going to know about pulp and paper. You're going to know about the chemical industry. You're going to know about textiles. And you're going to be the emerging expert in that area." That's a very exciting assignment, and if they get messages delivered to them from the DEP Administrator, the EPA Region I Administrator, or from Carol Browner, for that matter, that could be a very stimulating and almost revitalizing act.

• Mr. Orum: You want your permit writers trained in multi-media, but don't they need the same multi-media integration data to enable them to do their job? What would that be?

• Ms. Cummens: Frank answered that earlier. He submitted a three-page multi-media report for a facility-wide permit, along with his 76-page document for traditional stuff. He said DEP, right now, has no place to put that three-page report, and that's true. We're working on a massive information, integrated information system for DEP, and we have the screens. We have the template in conceptual design for where that multi-media report goes. But right now, that's not a live system. It's a concept on paper. We have the diagram, but we don't have a place to put it, yet, so it's a valid question. There are a lot of simultaneous steps currently going on.

• Mr. Dangermond: I was really taken by your comment that EPA is trying to get into the mode of doing integrated thinking, and thinking about an integrated system. However, if EPA wants to support this notion of an integrated system, they actually have to design and build a new system. Mark, you said you're not asking for a new system, but what I hear characterizes a lot of stove pipe, single focused systems, that don't relate, and are associated with work practices that cause industry to jump through all of these stove pipe information processes. To make this thing work, EPA needs to, re-architect their information system so that it's an integrated system. All of the re-education of people, while interesting and stimulating, doesn't mean anything if they can't have a system that their information goes into. People need to be educated how to look holistically at industry, and their work flow, but it doesn't really mean anything unless there's an information system that it all relates to. Database theory suggests that there are three things that need to be done: One, store the data, once, in a non-redundant form; Second, transactionally maintain it (that really means making the information system-to-work flow); And third, provide flexible, open, ad hoc viewing tools where different people, for different applications, look at the same data in different views. That's database theory. It's nothing new. We've known that for 30 years, but this is not the way the data systems are today. It's not an information system. It's not based on a database. There's no interrelationship. There's no support for multi-media viewing. The fact is, if there's not a real commitment to re-engineer the fundamental information system on which work practices and processing can take place (re-engineering of work), then it's just all talk. That's what New Jersey is doing, but there is no information system there yet to support the three-page report for integrated information gathering.

• Mr. Garvey: That's an important observation. We would emphasize there probably is a need for a new information system, not necessarily a new information initiative. There's a question here, however, which has not been resolved, and we actually are not offering a strong opinion on today, but that we think is important to consider: What is the relationship between EPA's federal systems, and a variety of state systems? A lot of the information is collected, particularly for compliance purposes, by states. They use it for their own purposes, but they also funnel it back to their communities in different ways. Yet, the question of whether the basic system should be a state centered system or a federal centered system, is not clear. Also, we need to think about whether either system could work efficiently for all parties.

• Mr. Dangermond: For me, whether it's a distributed system, a central system, or both, it's part of the architecture. But it's one data model, one transaction engine that serves all the different uses. That's really technical architecture. What's intriguing to me is that there are all these institutional things work practices built around something that's very, very old. And the fundamental thing someone hasn't sat down and figured out yet is what the architecture is. It's not the bureaucracy. The guy who just does the permitting, or checks the pipes, is totally motivated to do his job. I've seen these people. They take seriously and work hard. They are not someone you poke fun at. The guy, typically, is an absolute, dedicated bureaucrat trying to do his job. He just has a bloody antiquated system to deal with. It's mission focused on a single media. He doesn't have any way to get out of the block. So again, from a technology standpoint, modernize the system. Have a good architecture that meets all of these objectives. It can be done!

• Ms. Cummens: But the regulations have to be modernized to go along, because the systems were developed in response to the regulations. They go hand-in-hand.

• Mr. Sierra: How is the AFL-CIO looking at this whole issue of the environment being a tertiary issue, and elevating it to a level that can be addressed within these labor organizations and by the people themselves? Also, you mentioned tools from the EPA, that could evolve. What kind of tools from your organization could potentially evolve that might be able to link with EPA to provide that access and give users the ability to become more informed?

• Mr. Tingle: There's some information, but I'm not allowed to tell you right now. We are under a new administration and we are looking at environmental issues more seriously than ever before. The last regime also looked at them, but there were other concerns. This new one is basically focusing on environmental issues. The areas that we're focusing on, to get information out to our members, includes international labor meetings, on a yearly basis, where legislative groups meet. There are other political groups and departments inside of the international unions, that meet on a regular basis. Part of our new strategy is to make one environmental issue part of the agenda at each meeting. Once we move further along, we want to bring in the grassroots communities, the environmental justice side, some of the industry folks who are labor friendly, and some of the states who actually have people out there doing certain types of training. We want to tap into all those resources so we don't have to reinvent the wheel. These people are already known out there, and we need to give them the information about what's happening at the AFL-CIO. That's what we conceptually have in store, but I can't say when all of this is going to happen yet.

• Ms. Morton: I was thinking about the issue of not having a system to put all the data in, and of what was done in the New Jersey project. One of the successes that I see from this whole project was the community involvement. I got the impression that there wasn't that level of community involvement before you participated in this project. If nothing else, you provided the community with something they could use and understand, which is one of the ultimate goals anyway. Without a system you have developed a process so you can communicate with the community and they are able to understand, is that not correct? Did you have very limited community involvement?

• Mr. Gorski: We have a lot of community involvement, but not as a result of this [project]. One of the goals of responsible care is community awareness. But, the facility-wide permits were developed, in part, as a result of presentations to the community, and their responses. We initially presented it in simplified flow diagrams, but that was too technocratic. We then went to block flow diagrams. They liked that better. They liked the fact that what they could visually and conceptually understand, was incorporated into the permit as a result of community action.

• Ms. Hill: Going through your list of all the different permits that you had to apply for, you mentioned a number of permits that seemed to relate to water permits, yet didn't see any mention of RCRA permits. I was a little curious how the decision was made regarding a small media permit, which I thought was designed to pull all the permits in, had excluded a number of those permits? Are there other plans to work them in later? What's the status of the rest of those permits?

• Mr. Gorski: Singularly, the biggest missing piece in our facility-wide permit is the waste water discharge to the POTW. And the reason is that our POTW is an authorized POTW, one of a dozen, or so, in the state. So they, in fact, are the regulating authority. They write the permits, so I have a POTW permit. Pressure was indirectly applied on the POTW to renew the permit at the same time that the facility-wide permit was going to be done. We have categorical pre-treatment standards. We're doing what are called concentration-based samplings, and we should be doing mass-based. We should also be regulated as mass-based, but they're not. They still have technical issues that they haven't gotten through the system. They haven't gotten through the regular DEP with those issues sanctioned so they can regulate us the same way. Again, they got caught in the regulatory maze entrapped, and it kind of fell by the wayside. New Jersey also has toxic catastrophe prevention and a risk management plan. I'd love that to have been rolled into the permit, because it's coming anyway under Clean Air, and somehow we're going to have to get it in there. But that's another agency that's less cooperative than water and waste. So there are still a lot of regulatory barriers within the time frame. Holistically, all of that should be in the permit. When we reported out on the three-page report, the pieces that were not in the permit, were not reported out. And maybe I'd have a five-page permit if I had to report out everything that I do.

• Mr. Dangermond: Is there risk to the public, or to the regulatory authorities, in moving from 71 stacks down to one? If so, what are those risks?

• Mr. Gorski: The 71 individual sources didn't go away. They're still all in the permit, and they're listed with operation parameters. But what took five binders to put together, for instance, in the air pollution of 10 and 20 pages per permit, now shows up as one line on a table. I don't think there's a tremendous risk in that, because it's not that the information is lost. It's still there. It's probably easier to find in the new permit, than going through five binders and finding it. Certainly there's your standard level of trust is somebody not meeting compliance and not telling you. But you're supposed to be certified to do that.

• Ms. Bauman: But, didn't you say (and it's the same problem that would arise under a bubble kind of permit in the Clean Air Act) that some of your stacks or processes are obsolete? Others are very up-to-the-minute, state-of-the-art. A less responsible company might simply to choose not deal with the ones that are behind the times if their overall summary number made them in compliance. So it might remove some of the incentive to deal with re-engineering, or phasing out certain of the less wonderful parts of a facility. I think, conceptually, that's a potential risk.

• Mr. Gorski: Pollution prevention is good business. An obsolete process has more waste, and it generates more electricity, and it takes more manpower. It becomes less and less competitive, and it forces itself out. There's certainly a grey area of how you can run that cheaply and unsafely, if you're less responsible. That risk exists, but if you're really competitive, how long do you run the '57 Edsel before it costs more money than buying something new.

• The Committee took a break at 10:45 a.m.

• The Committee Chair and DFO re-convened the meeting at 11:15 a.m. Before the session commenced, the Chair asked Patricia Cummens to provide some background on a hand-out provided, during break, by her, for the committee (see Attachment (3).)

• Ms. Cummens: Since Frank brought up the issue of where multi-media information goes in the DEP, and since he pointed out the fact that it doesn't go anywhere, officially, yet, I thought I'd bring you up-to-date on an initiative that's underway in New Jersey. A lot of money has been invested to integrate the information systems that have grown up around the department. We've been working for years on the issue of getting a single unique identifier for all of the regulated facilities (key identifier) so you can go to one place and find out what programs regulate. And then link to the actual permit and compliance information for that one facility. This [handout] is a conceptual design, of the first phase of this effort.

• Introductions of the OIRM Panel were made. As each member was introduced, they were asked to give an opening statement prior to opening the session to a dialog. Key points of these statements include the following:

• Emma McNamara, Team Leader, Information Services Access Team, Enterprise Information Management Division, OIRM - Ms McNamara provided an overview and status of four current EPA Information Access Projects, including:

• The EPA Home Page - EPA is currently attempting to re-design the Page so it will be -more user-friendly and accessible. She indicated EPA's goal was to have the re-designed Page available by October 1, 1996, as well as having an improved, fully accessible search engine in place by the end of calendar year 1996.

• The 1-800 Number - This public access tool is in reality " 1-888-CALL-EPA". Although EPA has many information services available (e.g. Hotlines, Clearinghouses, Libraries, Public Information Services, etc.) There has not been one place where the public can post their call when they have general questions, and don't know where to start. The 888 number does not take the work away from the very specific, subject-oriented, hotlines. It helps to take care of those general phone calls that the public doesn't know how to direct. And if they find EPA hotline on hazardous waste or on water, immediately they call there. The Executive Steering Committee for IRM has funded Stage I of this effort, which involves developing a conceptual layout. The decision has been about made that the staff will be located in Cincinnati, since Cincinnati has a very good track record for some of the hotlines they're currently supporting. And we decided that not everything has to be in Headquarters. It could be spread out, too. We expect the hotline to be fully operational by January '97.

• Public Information/Information Resources Center - The current headquarters-based Public Information Center (PIC) will be merged with the Headquarters library to provide a one-stop entry to the public and EPA staff. The EPA Headquarters library is not open to the public, so they will not get the extensive reference services that EPA staff receive, but they get pretty good service in obtaining and identifying information sources. In the past, the PIC staff provided almost a triage area for the public trying to find information about EPA. In many cases, they had to be redirected to the Headquarters library for extensive research service, or for international type of information. This consolidation means both services will be in one place. A customer walks in and won't know if it's a public information specialist helping, or a reference librarian. Additionally, our Internet Services Center is being located there, as well, to assist EPA staff in publishing. With our move to the new Headquarters building, we will be including a Visitor Center, which will also be the PIC.

• Government Information Locator Service (GILS) - Came online in January of '96. It provides information and pointers to, and about, 237 major EPA information resources, including libraries, clearinghouses, hotlines, major EPA databases, etc. Since January, 1996, there have been 93,000 on-line accesses, and they are increasing.

• Patrick J. Garvey, Deputy Director, Enterprise Information Management Division, OIRM - Provided an overview of EPA's Data Warehouse efforts, including:

• The whole concept of data integration that Patricia Bauman and many of others have mentioned, has been plaguing the Agency for 20 some odd years. We have said that our problem is an extremely large reporting community. This problem includes a complex, fragmented environment for collecting and storing information, and a diverse (and hard to specify) user community. Who are the 14 million AFL-CIO types of folks who want to look at information? What kind of knowledge do they bring to the table when they submit a query? EPA is in a very complex environment, and our information is not that readily available, nor readily understandable, to the kindergarten kid.

• What do we need? We want information understandable to kindergarten children, high school students, the general public, EJ groups, and community placed-based groups. But I also want it to be understandable, or useable, to that scientist who's doing an epidemiological study.

• Our problem is that we have a bunch of laws that are very specific, and media oriented. We write an awful lot of regulations, but the state writes a whole lot of regulations on top of those regulations. And those regulations are by media. They all come down and they hit some regulated entity. They have inconsistent timing and definitions, and forms. And they're all put in separate databases. And whoever the stakeholder is, has to go and get some account number, and has to understand that database.

• Our suggested solution is a one point of access. Is it the solution of all solutions? No, it's not. We've got a lot of other problems that we still need to solve, but it's a solution we can take, through technology, and have not just the regulated entity, but monitoring stations and spills and other ecological points of concern, provide to their specific databases that they're constituency and regulations require and pull that information back, extract it and put it into a warehouse.

• Anyone needing technical data, or media-specific data, can do so through this warehouse. However, the warehouse will try to make the data much more understandable. We try to take the different definitions the individual media offices use, and try to normalize (or standardize) them. So, where you might use the phrase "spill incident", you might also use the word "facility", or "regulated entity," or "monitoring station." But anyone who still wants to go back to the separate specific technical ,complex, media-office system, has that opportunity.

• What the warehouse tries to do is provide a consistent data structure. We try to document that data so it's understandable, and you have the ability to go in and really search what a word or data element means. It gives you one-stop access to that collection. We can integrate multiple data formats in the data warehouse. You can store a photograph, or a video (the Office Air Quality System actually video- tapes their monitoring stations), or data itself. You also have the ability to generate, and store, derived products, such as maps or Statements of Quality.

• We currently have national media-specific systems such as RCRA, Superfund, TRI, and PCS. We also have a spatial data library which we have made available to all the 10 regions, and soon will be available to the public. We have demographic databases taken from the Census Bureau, that we've put in a common format. We also have created well-documented applications that provide products such as risk models, ecological assessments, or maps of geographic areas.

• There are five major components to our data warehouse: Facility Index System (FINDS); National Media Systems; Spatial Data; Demographic Data; and World Wide Web Interface Access Tools. EPA doesn't do everything, but our data is on-line, in one place, in the data warehouse. What does it mean? We've tried to standardize as best we can. We've tried to link, although, the Key ID system is necessary for us to do a better job of linking. We still need a better linkage system.

• Patricia asked what we need to do? What do we need? What are the next steps? More databases...my 1997 plan is to put the Safe Drinking Water database, RCRA's bi-annual report, the Grants Information Tracking System, and the Water Monitoring database in the Warehouse.

• Jacques Kapuscinski, CBEP Liaison for OIRM - Provided an overview of EPA's Data Warehouse efforts, including:

• Jacques provided an overview of EPA's CBEP Home Page.

• He then indicated that EPA currently has put together an agency-wide Internet team to think about what the Agency wants to put on the Internet, as well as how it would be accomplished. EPA has developed tools to identify the types of organizations accessing its tools. Initially, access was primarily other government people. Now, hits are coming in from universities, private industry, as well as private Internet addresses. Hits are now 50/50 federal vs other, and we're hoping that it will become more academic, private industry and local governments and other state governments. As a result, we currently have an agency-wide team that will focus on what we want to do in the future. The NACEPT meeting in Denver provided feedback from many people saying EPA is data rich and information poor. They indicated they couldn't understand the data; couldn't understand how to do a risk assessment; and let EPA know it couldn't tell them how to solve a problem. This has resulted in Wendy Cleland-Hamnett (Fred Hansen's assistant) asking a group of us to think about building a "store-front" of community-based tools to display some of our best tools available on the Internet, as well as having an internal Agency review process to look at these tools. This will provide one focal point, or a one-stop site, where tools can be described in a user-friendly way, and would be simple to understand.

• Once this system is up, our Regions and Headquarters Offices will be reviewing this tool. Once the internal review process has been completed, I would like this NACEPT group to provide your own feedback and guidance regarding the following questions: Are we addressing the right customers? Is the tool user friendly? Can you understand what we're talking about? Is it clear to you, as a user, that this can help you look, holistically, at different issues? Does it point you to information resources that can help you, in your community, identify super friendly mediation programs; understand how to manage well head protection; help answer questions about air quality problems, etc?

• We are also categorizing tools that might offer solutions to environmental risks, and tools that provide environmental information and data (e.g. GIS program information on Enviro-Facts.) There are a full range of tools being identified and included that we will be asking you to assess and evaluate for us.

• The Office of Sustainable of Ecosystems and Communities is developing an Internet Home Page that will be aimed at communities. Support will be provided through fax, phones, or the NET. We are also working on identifying information needs for communities. We are working with them to ensure that the tools developed will be helpful to them.

• At this point the Panel Session was opened to questions and dialog. Key issues and points raised during this session included the following:

• Ms. Morton: Is there one office in EPA that manages all the public access efforts?

• Mr. Garvey: No, it is not centrally located. As the Agency is decentralized, each AA ship has organized an Internet team. They all come together through an Agency Council on Internet, but each office has organized an Internet team to focus on their own client and office needs.

• Mr. Dangermond: You identified separate data repositories, and then the complete warehouse. You also made reference to a replication of this. I understand why that exists in the stepping process, but is that an architecture which will continue, or is it all going to be brought together in a single warehouse? In other words, over a period of years, will the separate, redundant, or replicated repositories, go away?

• Mr. Garvey: No, I don't think the repositories are ever going to go away. Let me tell you why. When Mark [Greenwood] sat as the General Counsel at EPA, they designated some data elements as enforcement sensitive. And some of the individual repositories in water discharge, or in permit violations, have certain data elements that are enforcement sensitive or confidential business information. I only extract, out of those individual repositories, the freedom of information set of data (those data that, if you wrote and asked me for, I could send you.) back that information. I do not put up the enforcement sensitive, or CBI, data. A lot of the individual repositories have that information for their regulatory work. Patricia Bauman made the comment this morning that industry initiatives do not totally replace regulatory necessary actions. Some of those repositories are necessary for certain reports that Congress legislatively has mandated. So they'll stay in. I now sit on five national systems executive boards. We are trying to talk them into an architecture that will make routine extracts less cumbersome and simpler to use. Most of those national systems are heading towards Relational Databases. This direction should help the Agency become much more efficient and much more economical in their architectural planning.

• Mr. Dangermond: I would suggest that may be the wrong architecture. I just keep thinking about an integrated whole where we could do integrated, cross-cutting work, and have it transactionally maintained. Over the long term, one might consider the separate databases as tables within a database environment. You would move, over the long term, to a vision that there is only one database, and that the database is accessible and useable by all the independent applications (whether it be congressional reporting or a regulatory function.) We know, technically, these can be managed. It gets you out of the stove pipe mentality which reinforces the very institutional problems that you currently have. The longer these legacy systems consistently work on just the single thing, the more you will remain in that mode. The architecture of your systems, in someways, is symptomatic of the stovepipe mentality, and it also creates some of the problems within the organization.

• Mr. Day: I appreciate that. I think, probably, what you've just said is something that's the kind of thing we'd like to see come in the report. That's the kind of issue we'd like to get on the table. I know Pat [Garvey] has thought a lot about the issue. I know a lot of people have.

• Mr. Dangermond: It's a natural evolution. We can accelerate it, and you can think about it and take stronger leadership in it. But whether it's this month, or six months, or two years, it will be a natural evolution of things and EPA might as well get with the agenda to get the architecture right. In this way we don't have such dis-related systems or alienation with the people that you actually serve. My second comment deals with the Home Page. A year ago I saw GILS and the Home Page. I really want to acknowledge the Agency for making a lot of progress. But Home Pages are in the midst of massive changes (just look at Microsoft's Home Page today and what it was a year ago, and you'll understand what I mean.) There are four main principles that are emerging:

• First, modern, state-of-the-art [Home Pages] are taking on a newspaper kind of a format, which really means that there's a reporting metaphor being used for their creation, as opposed to a traditional document format. It's like opening up the newspaper. There are always fresh stories, and there is fresh news, with hot links to everything else.

• Second is User Focus. Again, if you look at MicroSoft, when you go into the Home Page, you identify yourself, and the subsequent transactions, as well as the way it deals with you, is completely different.

• The third is a philosophy you should give some thought to, which is that the organizational structure of the Web Master, and current publishing guidelines, I believe, is going to die. It will be replaced by a publisher that has very high status within the Agency. In fact, I'm very appreciative that the Administrator got involved as she did. But I think that the Web Pages will take on a whole new meaning in the information society. They will be the place that all policies and information are launched from...they'll be the window which identifies the editor metaphor as more important than the Web Master. That means that someone has to have strong leadership that really represents the entire Agency, and all of its activities. They edit and organize the way that information is presented. It's not just publishing guidelines. There's somebody who really thinks in a cross-cutting mode about everything that goes on. That person is like an editor in a newspaper, in the sense that they are very sensitive to what the market wants. There evolves a user advocate, who responds to market pressures like a newspaper does. And management is totally connected to this person. Management has to view this as not something that's over on the side (a causative thing that we get some information out of) bu as the mechanism for our relationship with the rest of society.

• Finally, the Home Page is actually going to be the window into all other information. In that sense, it needs to be integrated with everything, not some sort of a "half-assed" way. That means totally integrated such that, the deepest, darkest data set in the separate data repositories are accessible through the Home Page. The concept of "drill down" is applied in the Home Page. Every mapping or GIS function, for example, could be activated by any citizen; every complex scientific analysis could be accessed by anyone through the Home Page organization, or the Internet.

The Internet will, basically, replace the desktop, and it will replace the workstation. The Internet is our new machine. And the Internet basically means that all computing will be bought and accessed through the phone company, so that you must diligently build your architecture on warehouse systems, and the Internet becomes the user's viewing mechanism. So, you must begin to think that the entire information fabric and communication of EPA, will be exposed to this media. I'm totally happy with what you've done, to-date, yet I'm not satisfied at all that you are thinking as broadly as you need to, with respect to this new media.

Finally, I'd like to point out that the Community-Based work is very exciting to me, and I'd like to acknowledge you, Jacques, for doing this. I really appreciate the way that you've done it. I think it's a good job.

• Mr. Orum: A short observation, and a longer question: The Short Observation: The most interesting thing I found on the EPA Home Page is that I could look up people's names and get their phone, mail code, and office. I could understand it. I think the links to the real data are extremely important. The Question: About 10 years ago, some Think Tank Groups got all the data they could find on particular facilities, for RCRA, Clean Air, Clean Water, etc. They put it all together by hand, and what they found is that the data does not provide for identifying where wastes are produced, and why. It didn't lead you to that. We heard some of the reasons for that, this morning. It's a certain information treadmill, different time frames...all kinds of different things. So, supposing you're 100 percent successful in getting access to current data on Internet. Now you've transferred that old problem from a few people in EPA's basement, to millions. What are the specific information things you are doing, that will break down barriers between EPA offices, support pollution prevention planning, rationalize, and potentially lead to unifying reporting for the industries? I would like you to think carefully about that. What are those things, beyond access, that are coming out of your efforts?

• Mr. Garvey: I think there's probably two areas that we're pushing on regarding the concept of data standards. We are trying to get the EPA community to name things the same way, but that whole concept of data standards is a tough nut to crack. Much of our terminology are embedded in our legislation. But we are working on a number of fronts looking at common reference tables. For example, we're just about on the threshold of starting a whole naming standard within the chemical environment. I think the Executive Steering Committee is going to have to grapple with how funding comes about, because many are regulatory changes. The bean counting that our national systems were traditionally created to do (i.e. the number of permits, inspections, violations, compliance types of things, etc.) don't get us to the real performance measurements that let industry and communities interact with each other to really do pollution prevention.

• Ms. Bauman: I think Pat [Cummens] said that supply generates demand, which really goes to what Jack was saying, that the Internet is going to be the new machine. We don't even know the uses to which the information will be put. We can foresee a different, and expanding range of public over time. So, the only thing that's certain is change and growth. The charge to our committee is to look at placed-based issues, but also cross-media issues. And they are, in effect, mirror opposites. One is cross-sectional and the other is longitudinal. Keeping that in mind leads me to ask you whether you think it is useful (as I think it is useful) to have a standing stakeholder user committee to give you feedback about the design, the content, the search engines, and all the rest, on an on-going basis. Because you don't want a static situation, and you may have in-house experts, but sometimes they don't always know what the user in industry, or at the grassroots, or environmental justice, or whatever, are involved with. I think we also have to remember, unfortunately, that there are people who don't have the Internet at all, or the Web, or anything of the sort. And so, we can't neglect the other means, because we will simply exclude a lot of people. Finally, a suggestion that really gets at Jack's point about drilling down and finding the actual stuff: GILS is a perfect opportunity. Why should it be merely a card catalogue? Why can it not be a gateway into the actual data itself that's described? At least that begins to be a prototype for the very kind of deep drilling that I think Jack saw as the vision for the future. GILS strikes me as the right place to begin.

• Mr. Garvey: We're trying to make GILS more than just the description of a document. We want to be able to make sure a document is available, and hot linked, as well. We've pushed pretty hard on that, and I think about 30% - 40% of the actual documents that are in GILS, are actually available on the Net. And we're going back to the document owners and asking them to identify where the documents are.

• Ms. Mcnamara: The thing to remember is that some of the sources of information that GILS currently points to, are actual services such as our clearinghouses and hot lines. So, you will link via E-mail or you will be given a phone number. But it also points to databases. Ideally, what we will be able to do through GILS is hot link (click on the name of the database so you get to the database itself to extract data you need.) I'm also glad you mentioned the idea of a Stakeholders Committee, because we need a way to ask the stakeholders, directly, what they need. We plan to conduct a baseline evaluation of the new Home Page, in the near future. We will include focus groups from all walks of life. I also view NACEPT as a wonderful focus group to provide feedback.

• Mr. Dangermond: You have to teach EPA's management that this [Internet] is the media for their message. They are critical in making this thing come alive. They are as important as the end users, because this is their newspaper. This is their TV shot. If you told the Administrator that she had an opportunity to talk to 20 million people on live TV, she might get rather excited about that. And if you made the point that EPA planned to delegate this responsibility to somebody that may, or may not, communicate the right message from an integrated EPA, you might get their attention. I know it would drive me crazy, as an administrator, if I were in a position where the message that's going out to our society is being delegated down to someone who, may, or may not, talk at the policy level. Also, Paul [Orum] made a good point when you asked if we were really dealing with the reorganization of how we do the work. It gets back to my going half-way there, to one database, as opposed to many. But forget databases...are we doing the right job? Are we really approaching the work flow correctly? Are we doing it holistically? Maybe all this beautiful new technology is just to better envelope the stove pipe work activities, and not to deal with the integrated environmental whole. And that worries me a little bit.

• Mr. Garvey: It worries me, too. Starting this week, we're going to have multi-media queries available through the Enviro-Facts Home Page. And it won't be just a single system. The problem is that program offices want to stay in their own turf. And I believe we need to have the CIO step up and say, "Strategically, we have an Internet which is our new tool, and our new machine, and our new platform for serving people. You've got to re-engineer for online net services."

• Mr. Day: It would strike me that, taking one more step back, IRM, in the end, can't run ahead of the customer. And the real customer question is one you eluded to: that management have a vision of how information can be a strategic tool. Management has to gain a perspective on that. I think this administration sees it better than the last, and the next one, I suspect, will see it better yet, simply because every manager that comes in has grown up with it a bit more technology. They are learning it because it exists. And that gets to your point that you can do it faster or slower, but you can't change the reality of what's coming. I think managers are gaining a sense of the vision faster, or slower, but they are going in that direction. The real question I have is whether we can do a lot of public access things that meet the strategic vision of information as a tool. Also, you asked about work process...are we doing the right things there? They have to rethink how they want the work process to occur, separate from information. They almost have to think about how we want to do business. Is it truly a community-based organization, or is it a regulatory, media-by-media, organization? What are our laws? Are our agencies, today, thinking about a generic piece of legislation that systemically goes back and looks at who EPA is and how we function together, as opposed to all the separate pieces? I think that we can go a certain distance in the IRM community, but then senior management also has to take that next step of asking who we are in our process, as well as asking what we are going to do.

• Mr. Dangermond: Are you saying that management needs to be better educated on what's possible?

• Mr. Day: I think that's a very big part of it because, as they see the vision, then they'll start to work the issue.

• Mr. Garvey: I think you're right on that, but I think they keep on thinking that [Information Technology] is not part of the Agency's mission. Yet, I think information is the only thing that EPA has. The states do all the darn work, and I appreciate the states doing all the work.

• Ms. Cummens: I think you're making a key point about the state level. I think at the EPA level, nobody is really thinking about the value of the information systems to support and facilitate the changes that need to take place. When we apply for EPA grants, we're also trying to push internally for other funding sources. Information infrastructure technology has to be a line item on the budget. It doesn't just happen. You write many conceptual things and goals on, "Here's what we're going to do..." and, "We're going to restructure this..." and, "We're going to have super inspectors that look at air, and water, etc...", and management just assume the information is going to be there to facilitate it all. The harsh reality is that it's not there.

• Mr. Day: In fact, that problem is rapidly being exposed by the GPRA (Government Performance Review Act) process. As the Agency goes through performance partnerships with states, it's discovering, "Oh, my God! We don't we have any information to back up this goal we just set!" I would say, however, that part of the answer to that question is that this is a customer issue. The customer of GPRA is the Congress, and OMB, and the public. And if they say, we want real results in our performance measures, and we want to talk about environmental use, and they use it in the budget process, and they use it in other ways, then it will happen.

• Mr. Dangermond: It's a vicious circle, though, because society has to be educated to the problems. Which is going to be facilitated by the fact that we're moving into an information society. Which means that people will want our society to reflect reality through these abstractions called information. And they will regulate. They will vote the right people in and law will be managed this way. I really want to acknowledge you guys for doing a great job.

• Mr. Day: Our strategic plan was premised on the idea if you put the information out, whatever shape it's in, you start the flow. Even if it's incorrect.
• The Committee adjourned for Lunch at 1:15 p.m.
• The DFO and Committee Chair re-convened the Committee at 2:45 p.m. The Committee Chair asked if there were any members of the public who wished to address the committee. No one answered in the affirmative.
• Mr. Davis indicated that the afternoon session would be devoted to reviewing the work of the committee, to-date, in order to refresh the members' memories and commence the process of identifying the top issues needing to be addressed.
• Ms. Bauman requested a clarification on timeframes for draft recommendations, next meeting(s) and the committee's time-table.

• The DFO responded that the committee, at the April session, had imposed a deadline of October, 1996 for developing an interim set of recommendations, to be followed by a full report, sometime after that. He also indicated that the next meeting would be in the December/January timeframe, contingent on the members' schedules, and the Agency's budget resolution.

• The DFO then indicated that Paul Orum had developed a model that might be used by the committee to commence the process of identifying key issues. He asked Mr. Orum to explain the model. (See Attachment (4).

• Mr Orum indicated that he and Ms. Bauman had worked on the model together because the Matrix developed at the July meeting was not very clear or indicative of the real issues. He first consolidated the original mission statement, with the mission discussed in July. He and Ms. Bauman then developed a list of what they felt the key issues were. Finally, he indicated that this was just a starting point, and that all the issues were open for discussion.

• Ms. Bauman added that she had been "struck" by how many of the issues identified in the model had been alluded to in the previous panel session. She felt this reinforced that the committee was "on the right track."

• At this point a general discussion of the issues ensued, and the key points of this discussion include the following:

• Ease of use [of the information]

• The need for an Information Clearinghouse. One Place, or "Center". One Integrated System with the "clout" to make it happen. One place for the Home Page, the data, and everything. An EPA clearinghouse with links to state data, local data, NGO data, etc.

• Better information sharing

• Identification of one responsible person. EPA needs institutional leadership in its top management of EPA, as well as the identification of those leaders.

• Senior management has to stay involved, not only to endorse the concept, but stay involved to ensure it actually happens. They have to be willing to make the tough decisions to make it happen and keep it moving forward.

• The Agency's CIO needs to have authority to go across all of the Agency

• An "Assistant Administrator for Information" needs to be established.

• Integration of information into the overall mission of the Agency

• Consistent data for the Agency's decision-making support mechanism. This is mandatory for improving accountability.

• A high level commitment to information integration is required if you are to successfully implement the Key ID, and successfully implement the architecture and infrastructure that's needed to facilitate internal and external communications.

• If regulatory flexibility is to succeed, how do we go from the current [stovepipe] systems to multi-media systems? How do you transition that, and how do you introduce incentives if, in moving forward, you anchor people to the past and they have to support both ways? Is there a way to introduce some flexibility where they're exempt from some of the old reporting requirements if they've begun supporting the new way of doing reporting?

• Can incentives be built into the process to get more entities, more regulated facilities, involved?

• Programs must stop being afraid to "let go" of their data.

• Data needs to be in accessible formats. Much of the data is sitting on mainframes, and no one can get to it. You can't do simple, ad hoc queries, so people duplicate it on their systems so its accessible, and useable, to them.

• Substance of the new direction is a key issue for EPA. If EPA commits to it, it has to stay with it.

• Legislatively, some things are doable. Much of the environmental legislation don't get too specific regarding data collection, other than talking about monitoring. RCRA may be an exception, but overall there is a tremendous amount of flexibility, if you go back and look at what the statute actually says as opposed to what's in the regulation. It might take some change in regulation, but we've taken the approach that we're trying hard to look for where there are areas of commonality where you could start to try to integrate and pull things together. It's a matter of momentum. If you get some movement, then you could identify areas where the Agency might need to talk to Congress.

• More case studies, including lessons-learned, need to be published and made available to industry. Success stories go a long way to selling a process. Currently there isn't much out there for industry to point to and sell a process internally.

• A transition plan needs to be developed to move from where we are to an "XL" type of approach. Such a plan must include information. The Agency is not currently doing this. It has not done a good job of understanding the information component and requirements. The information component is the backbone for the process.

• At this point, the discussion focused on issues revolving around the Agency's current systems and "stove-pipe" process. What follows are key points about that dialog:

• The Agency needs to look at a new information architecture which is supportive of integrated work. This includes integrating communities, industry, and other national and local agencies to the Agency. It needs to develop one single data model. But to do that, senior management needs to personally commit itself to this effort.

• The data integrity of the system is the essence of the problem that we have. And that's not an easy thing to cosmetically fix up. Reporting is good. Politics are right, but the essence of the organization, which the information really represents, is messed up. We have a stove pipe organization and stove pipe regulations which the information systems clearly represent. And there are arguments about whether the information systems actually are the inhibitor to information in organizational integration. Have the information systems actually become the literal barriers between organizations? This is inconsistent. You have redundant data collection, redundant data transaction work going on, double entries, and with redundant books, you have inconsistency. The moment you have a single data model it all comes together.

Q: Realistically, you've got media programs that have to respond to specific regulations that are out there. They measure success based on that counting process and the individual media- specific work that they are doing. So, how do you convince management that it is a good idea to invest? How do you get them to go beyond that? To look to that future?

A: Maybe they don't care about doing One-Stop, or they don't care about integrating their work practices. That could be a policy decision. Obviously, it is a policy decision as it reflects the Agency's work practices now. One way to look at the way policy, and EPA, really is, is to look at the condition. That is actually a reflection of what the policy is. The current policy of EPA is, obviously, to reinforce with millions of dollars every year, stove pipe systems. It isn't "Trying to do better." You're not. You are not doing better. You are reinforcing with millions of dollars of commitment and staff, and cheating the poor bureaucrats who are stuck with that. That's actually the truth. And when we accept that, then we can ask, "Do we want to change the policy?" Maybe, maybe not.

Q: The last NACEPT report started with, "EPA will fail to achieve...these major new directions, if you don't start to change data integration". You went on to say, "You will fail to achieve ecosystem protection...if you don't start to work on data integration."

A: But we don't want to state it as a threat. The way you read it was almost a threat. Another way to say it is that "Management appreciates." "I appreciate it" is simply to say, "Here's a tradeoff so you can continue the existing policies." And "We won't be able to achieve these," which is totally okay, because we're not achieving them now. And then, "Here's what we could achieve if we brought this new context into being." Managers are paid to create what's not. They don't get paid to create what is. So you respond to them by talking with them about the opportunities for creating something new. And that will get them really excited. And that's a real job.

Q: In fact, it's always two questions. What will happen if I don't do this? And, what do I get if I do it? Those two questions, and the answer, "You're not going to get ecosystem protection if you don't move in this direction. And if you do move in this direction, look at how we can change our environmental protection." Now, the question, becomes, "Do we change the policy or not?" I think most management has a lot of things on their plates. So the question for them is, "Is this problem of sufficient gravity for me to expend my time on it over the other set of things that are also asking for my time?" How do you get senior management to care enough about the system to stay involved to make sure it comes and does, what you want?

A: The response is to do prototyping and keep them involved by showing them progress. Don't go away for a year doing studies and then come back and have the system not quite work. Prototype every six weeks, give them a five minute briefing, and they can then see what progress really is. That's how to keep management involved. If you're not doing prototype as a methodology in systems development, then give up now, because it isn't going to work.

A: Another issue is money. When we look at all the different programs that are operating independently within EPA, we also see duplication. There has to be a cost savings, and that, it seems to me should appeal to senior management.

• All of this comes down to a belief system. It is possible to integrate databases into a single database and still be responsive to each of the individual regulatory requirements. There should be a separation of the logical model versus the physical model in the database. The physical model would achieve integration, whereas, the logical model is supportive of the individual regulations or work practices. With a clever information architect, they can actually achieve stove pipe looking systems in an integrated data model. That is the first step on the way to achieve integrated work practices. You first integrate the data model. Instead, they're saying we're going to integrate the view, but keep the separate systems. So it's exactly backwards. And what I'm saying is it's much more expensive to do the opposite.

• All the efforts being spoken about are performance based, but if we don't have the information to measure performance, they won't work. You need all the decision-making results and accountability.

• The issue of integration of data beyond access should be listed under the rubric "EPA leadership".

• Under regulatory flexibility, we need two things from industry: Information to verify progress and results; and, the resources for technical assistance.

• Feedback loops for data quality are needed. When the data proves to be wrong or incorrect, there needs to be a way for having corrections. If that doesn't happen, users will be very frustrated.

• The useability and interpretability of information is problematic. If the information is not useable or straightforward, it will be misinterpreted, and that creates more problems. One specific recommendation would be linked to the Government Information Locator Service: Go beyond being just of a card catalogue, look at it as a gateway. Whether it's the watershed, urban, or the tribal level, put those resources out there so that people can get to the information directly.

• Form a standing user advisory committee that has a permanent existence, and helps the Agency, particularly its leadership, by giving on-going feedback, reactions, and comments about what should be accessible, how the new design of the architecture should work, etc.

• We should publicly support the Agency's efforts on behalf of pollution prevention. We've talked a lot today about permitting, integrated permitting, compliance information. The real "results" are not the stove pipe we've talked about, but rather, the actual changes in the way the environment looks that we all live in. If we're talking decision-making results, accountability, and placed-based, why are we doing that? We really want to change the environment. And we want to engage in real prevention that makes this a better place to live. We should go on the record, because we really are looking for information that's going to help us document improvements and trends that are going in the right direction. The driving engine really is pollution prevention, and that is the goal of environment protection. Its management is a component of environmental protection, but only a component. As we move into the new age where we have regulatory flexibility, we care what's going on at the community level, and we acknowledge that pollutants don't stay in the same place, but move across media. Our goal is pollution prevention, and information management efforts should support that goal.

• When we talk about the framework that EPA needs to build an integrated information, we've talked a lot about the stakeholders accessing information. But we also have to address the issue of the stakeholders providing information. How does state-gathered information, as well as information from local and non-profit levels, fit in with EPA's integrated information system?

• Connect programs and related information systems to the fundamental goals of the Agency. By connecting the programs and information systems to the fundamental goals of the Agency (which are environmental protection, stopping pollution, and prevention), virtually every information system has that mission statement tied to it and people won't forget it.

• Information in multiple languages should be encouraged and pursued.

• EPA should be careful about the information "have not's". It should make a particular point of outreach to libraries and other intermediaries that can help and work with the general public. This would include the '800' numbers, and training modules for librarians (because sometimes they're the only ones that do have the Internet access).

• At this point, the issue of Trade Secrecy was raised. Key points of this discussion included the following:

• Ms. Bauman: This is a sensitive issue. We heard this morning that sometimes whole data sets can be essentially unusable if they contain a lot of blocked out information that's been claimed as trade secret. So the process of accountability of determining results of assisting decision-making (outside the people in the federal government who have access to information) can really be slowed down or hindered by trade secrecy issues. The Agency has worked on this, including setting up task forces and work groups. This is not a new problem, and there are already some areas of consensus about how to handle it. Although EPA has had work groups, Paul and I bring it up because the problem of trade secrecy underlies a lot of problems of access, accountability, and measurement of results. This makes it worth reconvening a group , at a high level of multi-stakeholders, to identify what is a real problem, and what isn't. TRI has been successful, so I don't think the trade secrecy problem is unsolvable, but there are conflicting interests. There are differences of opinion, we should flag secrecy as a problem because it affects the "drill down" process, as well as the whole problem of public access and accountability. That's why it's been put on the table. Not that we have something definitive to say about how to resolve the problem, but to say it's got to be resolved if we want these other objectives.

• Ms. Morton: I have my own feelings about trade secrecy, and I thought that one of the ground rules for this committee participation was that we would check our advocacy at the door. I heard Rex [Tingle] mention the issue today, but I didn't hear that from anybody in Denver. To me it's not an overwhelming issue that I've heard on a repetitive basis, enough to warrant being included in this discussion. It has such strong advocacy connotations associated with it for some of us, that we could get bogged down with it.

• Ms. Hill: I don't think Trade Secrecy is something that's ever going be resolved, because it's a process. If you look at the number of times that it becomes a stumbling block, the onus is on the industry that has claimed the trade secrecy when someone comes back and wants to request that data. It's not an issue that's ever going to be completely resolved. So I don't know the calling for another group is good use of resources. If a corporation chooses to claim trade secrecy, the Agency accepts that at face value. But if anybody comes in and says, "I question that," then the heat is back to the industry to justify why they're making that claim. So it's hard for me to imagine how a group can come up with some other process than the one that currently exists.

• Ms. Bauman: I think it depends on the law. The laws about trade secrecy vary all over the board.

• Ms. Hill: I'm not familiar with one that doesn't basically put the burden back on the facility.

• Mr. Orum: There are, though, different models. What I had put down was that some of the databases have big trade secrecy problems at TSCA. And everybody knows that. There has been some work done before. This is one way to go forward with working on the issues, without our getting into it. There are certain successful models out there. I think protecting trade secrets is extremely important. But I don't really think that if you set things up right that it really gets in the way of the information. There are ways to set up your information system so that it doesn't get in the way of what you want. And this was basically a format to not to get us bogged down into it but to simply acknowledge that there had been a process, and to say EPA needs to keep going with that. There needs to be more work done.

• Mr Moilanen identified key Tribal issues as follows:

• The tribal issue needs to be on the list. It's a pretty simple one to solve. And that's Internet access. Many tribes don't have that access. that do not. Once they do get access, tribal environmental managers will then be able to identify data gaps, and identify problems with data integration.

• Expansion of the online library of EPA documents. Tribes have trouble getting such things as Clean Water Act, Clean Air Act, etc. We get bits and pieces here and there, but we don't see the whole Act sitting there.

• Easier to use GIS tools, with pull down menus, and windows-driven menus. Our tribe has a gentleman who's three-fourths time GIS. Most other tribes have one tribal environmental manager [to do it all]. Most of them don't have any training in GIS. Something simpler would help.

• Telecommunications issues, including resources to get the technology to be able to access the Internet, might be resolved through EPA's current efforts to fund connections to commercial Internet servers through EPA grants. EPA needs to do more on this.

• The meeting adjourned at 5:00 p.m.

National Advisory Council for Environmental Policy & Technology

Information Impacts Committee

September 10 - 11, 1996

Meeting Minutes

Meeting Site: Dupont Plaza Hotel, Dupont Circle, Washington, D.C.

September 11, 1996:

Attendees: Patricia Bauman, The Bauman Foundation

Patricia Cummens, New Jersey DEP

Jack Dangermond, Environmental Systems Research Institute

Tom Davis, Tom Davis & Associates

Suzanne Hess, Hunterdon County, New Jersey

Patricia Hill, Georgia-Pacific Corp.

Michael Moilanen, Mille Lacs Band of Ojibwe Indians

Cheryl Morton, Synthetic Organic Chemical Manufacturers Assn.

Julie Norman, Headwaters

Paul Orum, Community Right-To-Know

Joe Sierra, DFO, U.S. EPA

Mark Day, OIRM, U.S. EPA

• The IIC Chair, Tom Davis, and the DFO, Joe Sierra, officially opened the meeting at 9:00 A.M., September 11, 1996.
• The initial dialog centered around the issues of Confidential Business Information (CBI), and what the committee should say about it. Key points included the following:

• Mr. Orum: There should be a place holder for CBI, and the Committee should not get into it. It was raised by Rex Tingle, as well as by others at the Denver meeting. The place holder should say that CBI is important. There are laws where you have successful models, as well as unsuccessful models. There has been ongoing work, and EPA should continue that work. Also, CBI is an issue that overlaps all three key issues we have identified (Decision Making, Accountability, and Results). The basic information that a firm needs to make decisions will improve results. It's important that the right sections of the information be disclosed for accountability, which then leads back to decision-making.

• Mr. Morton: I think the Agency should continue its existing work. For instance, they're now looking at whether a state should access CBI. Once concern, however, is that a lot of this information is going out and being used for competitive purposes. Other companies are getting it for their own purposes, including foreign companies. Information, although it may not be claimed as sensitive (or confidential) business information, could be used in a competitive way. This also holds true for enforcement information. There should be some thought given regarding what kinds of information should go on the Internet.

• Ms. Bauman: I agree, We're saying let's build on existing work. Let's look at it. Let's involve all the stakeholders. So I think that would be fine with me.

• Ms. Hill: I think we need to acknowledge that there is information that for some companies, and some processes, will be unusable. It's my understanding that there are a number of companies that, because of the process they use and the competition with other firms, may be hurt by disclosure. I wouldn't want to support anything that said there's information out there that in some categories doesn't have to be treated. While the burden is on the company to justify why it should be safeguarded, there has to be a process. I have no problems with stating that the Agency needs to look at existing statutes and make sure that there is a fairly tight program in place so that people can't just label information as CBI as a way of not sharing information. But you have to look at the international competitive issues, and the fact that everything will probably end up on the Internet. So, as long as we carefully phrase this to acknowledge that there may be some things that fit into a category that have to be treated separately, then I agree.

• Mr. Orum: I think we can do more than that. I think the that CBI need not interfere with effective information programs for decision-making and accountability. And my bias would be to add that CBI protection is important, but there are better and worse models out there. We might list them. TSCA's probably generally agreed as having more problems. TRI has less. The intent is that CBI should not be interfering with information disclosure. Start with the information disclosure program and then see where CBI gets in the way. That was my intent.

• Ms. Bauman: A balance needs to be struck between the legitimate needs for companies to protect CBI, and the legitimate needs of the public and decision-makers to access information. I mean, maybe we just put it out like that.

• Ms. Hill: And I think something along those lines is exactly what we're looking for.

• Mr. Orum: The only other comment I would have is that, in my experience, enforcement is a different issue from CBI and sensitive information. I think all the enforcement records should be readily available.

• Ms. Morton: But accountability is true for the Agency, as well as companies. You tell companies they are obligated to provide a certain amount of information, but you're telling the Agency it can put out anything that it wants. I think there needs to be some accountability on the Agency's side with respect to information that goes out. Not just data quality, but what kind of information is being provided to people, and how are they going to use it? If you don't want to do enforcement, that's fine. But there are a lot of foreign companies getting information on U.S. companies from TRI, and they're combining it [with information from other sources] and they're figuring out how chemicals are being made. Then they take that information, and they use it for competitive reasons. No one is really sure of the impact of this sort of thing, because this it's all so new. But we can't ignore it. The Agency can't just claim "Information is not CBI, so put it on the Internet." There needs to be some accountability on the Agency's side, with respect to giving thought to what kinds of information are going to be put out. Although information may not be claimed confidential, it can still destroy a company if it is not safeguarded.

• Mr. Davis: I think Patricia's point about striking a balance gets the point across without being too specific. We can't make a decision, but we can at least identify it as an issue and go forward from there.

• Ms. Hess: I liked what Allen White said regarding this whole issue of CBI. He said the focus should be on the shared interests of both industry and the EPA, and that environmental information should inform, and should also be linked to competitiveness. There's a fine line there. There's got to be that balance.
• At this point, the general discussion moved on to issues regarding access to information and the tools required. Key points of this dialog included the following, and are grouped by each major topic/ category discussed:

• GILS:

• GILS should be expanded to be more than a card catalogue. It's a point of entry that would get you to other major resources. A recommendation from this committee should be that the Agency should look at ways to enhance GILS.

• I was gratified, and in agreement, with the concept of using GILS as a prototype for the process of drilling down to the actual data itself. That seems to be the general goal. GILS would be, basically, meta data. It should be reconfigured to go beyond the "card catalog" stage.

• When originally conceived, GILS was not envisioned as a tool to be made accessible on the Internet. Although it was originally intended as a "pointer" to other information resources, the technology is in place (Internet, etc.) to go beyond that and "hot-link" to the actual data. Those links need to be encouraged.

• Whether the [access] tools are GILS, Enviro-Facts, or '800' support access, or whether it includes the whole concept of one-stop shopping and multiple means of providing information (including faxing, hard copy or electronic transmission, etc.), we are talking about multiple language tools being available. Does it make sense to perhaps put all of those together under that umbrella of information clearinghouse and ombudsman and say, "The committee recommends continued support of those? You've made a good start at developing some tools as a central clearinghouse, but you've got to make it more cohesive. You've got to make it more structured. You've got to define the tools better. You've got to continue to improve those tools, so that the tools that you've got now are good, to a point, but they need to expand."

• The two functions should be separated. One is an ombudsman function and one is a clearinghouse function.

• They should be called access tools, because a clearinghouse suggests something that's a little old fashioned where somebody collects information and then sends it out. That has its place (like a pollution prevention clearinghouse, or a data integration clearinghouse.) But GILS become an information access tool. An 800 number is an access tool, as well.

• Information Access:

• EPA already provides access for most of its databases. The problem is that the software that goes with them is so unusable that you can't pull any results out of them. That's the basic problem. The data might be there, but the method to access it is not.

• Effective user friendly software is not available.

• The way that the software industry is going is to something called "Object Oriented Technology." In lay terms, this means that the software and the data are one. You have an object like, "I am a pollution site. Ask anything about me." And this piece of data travels with the software, and the software is smart enough, or the data is smart enough, to be able to respond to questions. In other words, in the past, there's been data and there's been tools. And they are now putting these together, and they call it an object. The way of the future is that data will know about itself and be able to express itself. It will know how to list itself. "I'm a table, and here's how to make a list of me." The methods for representation of the data will travel with the data. This is future, but it's within a five year time horizon of any information architectural revolution.

• What's being said currently is that software is too hard to use. And that's true. But software is getting easier. That's not something that EPA is going to control -- no software industry will. But I also suggest that, in the future, these two worlds will come together. When you make a request of some information, you'll get the information, and the software will come with it. D.M.A. is an example of this. They are actually releasing data sets which have a viewer with the data. And what's not obvious to the person who gets those data sets is that this really encapsulates data with software. And the data really becomes smart. Although it may be abstract, in the 21st Century all data will know about itself.

• Currently, software is not necessarily that hard to use. It's just that there's so many glitches in it that it gets frustrating. And there are so many road blocks. The statement from this committee should be, "Software released with the data, at EPA, should work right."

• User Standing Committee

• EPA should establish a User's Group to review its data products and its software initiatives. This group would include industry, state and local government, tribal representation, NGO's, etc.

• This is actually becoming a popular concept. D.M.A. is doing it. They're actually asking their users. In the past, D.M.A. would make a map and say "that's the map." Then the guys in the field would try to figure out how to use it. Now that they've moved into the electronic age, they realize there's a huge gap in useability. And they regularly assemble, annually, a meeting of all of their users (between 500 - 1,000 people.) Part of the user group that we're talking about would actually address the citizen outreach.

• It should be a users group, not a committee. And it should not be just an ad hoc, one shot, thing. It needs to be an on-going commitment to maintaining that user group.

• They would become ombudsmen to receive the complaints or criticism of a particular piece of software. They would become beta testers that would check things out, and give guidance. It could be modeled very much after a commercial software house, where there's a stage of different relationships.

• A possible vision statement regarding community involvement could be: If EPA went from trying to regulate, to the idea that they would really be serving locals, then what would the big service be? It would be an information and guidance service. Then what better way to do that, than to get people together locally and regionally to discuss the issues. There would be a national meeting, as well as regional meetings, that really get the people starting to talk about methods for application of information to problem-solving and the environment. And there could be lots of different sides to those discussions. The last of three days would be a workshop. There would be certain kinds of training on methods which would address some of the issues that are harder to deal with. The concept would be for real end users to get connected to EPA; have EPA accept that its job is to serve real end users (and that they don't have to do it all themselves); turn the process over to the "network of real doers,"; and EPA just facilitates the meeting and provides the information, and some tools.

• Public Access:

• We were told that in the "new EPA building" there would be an information center. That seems to be four or five years down the road. Do those things work in Washington, D.C.? Is a information center that is a big room with information stuff, really used? It seems to be more for tourists or local business people.

• The Agency should be encouraged to ensure that similar centers are available across the country. The centers would include direct, on-line access to information, with the appropriate tools (PC's, GIS, etc.), as well as '800' number capabilities, fax capabilities, Internet capabilities, etc. The main value of that 800 number would be just to connect people with somebody in a regional office if they didn't know who to call.

• Maybe we want to make the point that if they're going to do a public access center as that kind of the visible thing for people to drop in, that there be some sort of technology there that will tap into Enviro-Facts and GILS. In that way, people who don't have Internet access can stop in and get the access there.

• We also talked yesterday about libraries. There are depository libraries in every congressional district in the land. New Jersey has done a wonderful job of using libraries as nodes for public points of contact.

• One on-going project distributes data and Arc-View software to nonprofit groups (primarily environmental nonprofit groups and libraries.) Groups get the software free, get the CD's of data, and academic institutions provide cost effective training. As a result, there are now pockets, all over the state, now where people can go to get access to the GIS data. Monmouth County has an extensive project in one library, where a very customized Arc-View was put together and sits on the PC in the library. People can stop in and create their own maps, as well as ask their own questions. They finally got funding to put the printer next to it so they can now print a map for people to take with them. There's been growing interest from other libraries. Quite a number of them are mimicking that original model.

• A key person needs to be designated at a library in order for it to work. Just putting a computer, and software, in a library will not work. An example is the St. Louis Public Library. One person supports their public access efforts, and it's become a showcase of public access to government records.

• As was pointed out in Denver, however, a lot of people in our communities don't go to the libraries to get the information. They look to community centers, churches, or other alternatives. They might not have a library immediately in their community. So how do you deal with that?

A: Examples would include grants for community-based non-profit organizations (whether churches, libraries, or schools.) Well, I hate to say it in this day of fiscal austerity, but, you know, a small grants for community-based nonprofit organizations of whatever kind. They were a church, or a library, or a school. New Jersey has used grants (including software donation) for non-profits and libraries. They have even funded a church. The only criteria for getting the software is that hey have the hardware. They also have to commit people, by putting actual names on the grant applications, for the training, and prove they have the hardware, but those are the sole requirements.

• EPA Dockets have rulemaking, documents that the public might want to review (e.g. Rules being proposed, and public comments pertaining to the regulation process.) Each major media program has a separate one (air, water, etc.) that's run like a library. Do you have any recommendations regarding these Dockets? If you have a physical library and a physical clearinghouse, is there any value in bringing those dockets together with the library and the clearinghouse?

A: Is there any reason they couldn't be put on the Internet? You could do notices, comments, rulemaking, etc.

A: You should be able to bring together rules, reports, data from key environmental statutes, and the Docket information as well. There are two key things regarding access: One, that the search engines are linked to the underlying data (to support the 4 P's - People, Places, Pollution and Prevention), and Second, that you have real people who can guide you through it all. Envision an '800'number ombudsman is somebody sitting there with a headset on who knows where everything is, gets the same kinds of questions, the unique ones all the time, and can help you whether you have a phone or a computer. The critical thing, however, is to have a human there to guide you through the process.

• It almost sounds like what we're really talking about is a multi-media center that has an ability to take walk-in, phone calls, or electronic queries, at a core body of knowledge that is together. No matter which way you come in, you get the same answer because you have the same access to the material regardless of the method of arrival at that body of knowledge (and presumably this would all be available on the Internet.)

• The Denver (Region VIII) public access model is interesting because it has integrated their library. It also has hand-out information, terminals, and an '800' access number capability. They are physically integrated. And I'll bet you it's hard to replicate because it's probably very much tied to the people in their culture.

A: That is in fact the key issue. But it seems like that's the vision that I'm hearing you all talk about: Bring it all together so that how you come in is not the issue, because it's a coordinated body of information.

• In Denver we heard the need for technical assistance beyond librarians. We heard about the people who are really in contact with the neighborhoods and the particular problems of an area. The job description that seems important is people who are not just based at the EPA's main office, it is the other people scattered, who have expertise, say, in software, and who have the motivation because they are part of that community. It would be a much broader team than just librarians.

• That would include the model mini-grants that New Jersey has, combined with full Internet access to everything, including the Dockets of Notice and Comment. Although it hasn't been mentioned here, the needs of rural people, as well as the needs of people living on tribal lands, are quite acute and different. Not everyone can get to a site (like Denver or St. Louis.) We have to be very mindful of that kind of geographic discrimination. Neither EPA, nor its staff, need to be responsible for everything. Small community-based grants can be used to train people.

• I think that the basic thing that people would need not to burn out in the ombudsman job would be the underlying information infrastructure needed to get the answers.

• AA for Information:

• One of the core problems identified with the '800' number is maintaining the information. The ombudsman would know what information is being put out, as well as when the document is being "refreshed", or a new document is being added. Also, they would be aware of new publications, new databases, etc. They would have the ability to say, "Here's all my assets...let me tell you about them." It's another thing, however, to get Programs to constantly refresh their information and maintain it. That's a real core problem for us. The issue is resources. The one-time support for an initiative is one thing....getting programs to devote someone to maintaining, over time, is something else.

• This discussion simply underscores the importance of an 'AA' for Information. That recommendation is vital because you need a leader, a driver, and a champion.

• The '800' ombudsmen will fail unless you resolve the integration issues.

• Going further still, in the preamble to our report we should say that none of these initiatives will succeed without the leadership and total commitment as would be reflected in the creation of an AA for information.

• One person needs to be responsible for conducting an assessment of all the existing libraries, hotlines, Dockets, etc., and determine what can be done to consolidate, streamline, develop an appropriate information architecture, etc. This would include communication, data, links, etc.

• If you deal with a reporter who wants to talk about a particular area or facility, or a citizen who wants to organize information for their watershed, again, the underlying thing is you need to have that data integrated for them to succeed in doing that. So, one interface, one integrated data set is one way to get there. And the underlying information architecture needs to be there to make sure these efforts succeed.

• The biggest barrier for an AA for Information is turf. We've heard that time and again. You can say the same thing about big corporations or little corporations. I think we need to make a strong statement that turf needs to be overcome.

• From a regulatory standpoint, however, turf needs to be delineated. However, if you look at the concept of what community-based environmental protection, including what it's supposed to be and the direction the Agency is underscoring, you wind up with the vision identified earlier of going from regulating to servicing locals. The issue of turf needs to be linked to that vision. Additionally, turf is related to the ability to use the data and have individual systems. Nothing we've said indicates that users shouldn't still have systems that reflect their individual needs. The data, however, should be integrated and in a model that works. The data should be the resource that EPA manages corporately. Systems can still reflect individual needs and turf.

• There is a lot of relationship between ownership and so-called "turf". Because somebody says, "I own this, I'm going to make sure that this company gets regulated. That's my whole job, and I don't want to let any information stuff get in the way. I'm going to make sure my job gets done." I love that. You might say there's some negative aspects to it, but it's a wonderful thing when you can see somebody so identified about their job, it's motivating, because they really own it. So there's a conflict between ownership and something called "turf" when we look at it. There's a different school of thought, however, which says you can integrate the information and make it work without interrupting, or with minimal interruption. And that really means bringing the information together in a cross-cutting way. Ultimately, the result of that information architecture is that "turf" can actually have more maneuverability into the information underneath it.

• I suggest that one of the reasons IRM, as a profession, has many of the turf battles, is because we haven't delineated what is needed to run my job. Which is the system, and what a corporation needs, which is the data. And our ability to manage, as a profession, hasn't grown or matured to the point necessary.

• Key Identifier:

• The Agency should keep moving forward with the Key-Identifier.

• The Committee calls for the Agency to demonstrate real leadership in the timely enactment and implementation of the key identifier.

• Some useful key identifiers would include: Organization facility regulatory status; Geographic Location.

• If 10 percent of what I have to identify, in my state, is an EPA facility, I need one ID that will work for EPA and the state. It may be as simple as the standard two-digit state identifier in front of a number, but whatever it is, it needs to be considered in the design.

• It does not good at all, to a state, if it's only a federal ID that's used federally. Then the state has no buy-in, no reason to support it, and no reason to make it accurate. If, on the other hand, the ID allows a state to put all of their facilities under the same system, then accuracy will increase tremendously. If it is actually valuable to you in the transactions you do daily, you will make sure it's good. And that means EPA needs to accommodate every state facility in the design (although not necessarily in our database). But the design has to allow it. I would go so far as to suggest that there ought to be a national repository of all the facility IDs, including all the state facilities.

• There should be a national repository for the record of all facilities, and it should be transactionally maintained by the states. In the long run that's the right way to go. The states would be in total control of their data, but there would be a place where it comes together so that anybody in a neighboring state, industry, house buyer, etc., that needs to look at something, can do so.

• When will the X,Y Coordinates be completed, and will they be publicly available?

A: They should be completed by December of this year (1996). Everything will have been entered through address matching. It will be part of EnviroFacts. Loading is supposed to start in January (1997). After that, some states and regions will be ready to load even more accurate data than the address matching. For example, the New England states have completed all their public water wells through the use of GPS devices. They will start to load that data as soon as we've completed our part.

• The importance of Key Identifiers can't be stressed enough. This issue needs to be resolved. But it's also important to stress the use of other Key Identifiers as well. For example, if you are interested in gathering information about hydrofluoric acid at oil refineries, you should be able to call the pollution prevention clearinghouse, and they should be able to easily search for hydrofluoric acid at oil refineries. Or if you were interested in just the oil refineries, or just the hydrofluoric acid, no matter where it's used, you should be able to search on that.

• Key Identifiers will vary from group to group. Your view may be to search by facility, but someone else may want to search by chemical. There are natural views of the data. There are some key identifiers that will make those natural views work. Facility, Location, CAS, SIC Codes, etc., will give people a fundamental different view that they can work with. Key identifiers, in EPA, include all of those identifiers, so you can link chemicals across programs (which, as you know, you can't do today), link industry across programs (which you probably do better, right now, than any other thing we've got), and SIC Code are probably the most standardized coding we use. But the point of Key Identifiers was to be able to link across the programs at all these different cuts rather than just by facility, because if you get all the facilities linked, but you still can't search for a chemical across the systems, then you've fundamentally failed to get at some of the basic issues.

• Do you have a solution for the state and federal integration?

A: I don't think it's really that technically hard to solve. I think we should let the states run the ID system. We have a repository where they put it, but they run the ID system for their state. They assign the numbers. They use the definition. We agree on the definition of what it is, but they use it. They assign it, because then it becomes transactionally based for them and it will be accurate. And we don't worry about the states' numbering systems, other than making sure there is some standard length format, and some other minor things, so that it works. I'm not going to swear to you that we could get all 50 states in that way. But you can get most of the states, and that will be the most accurate. For the states who don't want that job, we would have to do it for the federal facilities, and it will be less accurate and less valuable. But there's no way to force it on the states. In this day and age, we're not going to force this issue on the states, and win.

• EPA could, however, provide some guidance. New Jersey's been through a few iterations of what the facility identifier should be, and I didn't agree with their first start. I agree with what they are starting to do now. I also agree with Massachusetts's model. EPA could consolidate some of this and say, "Here's some ideas. Here's some models. Here's some concerns if you're going to go with this route." In terms of just an identifier, EPA should say it'll be up to the states, but there will be a standard format. The states can take the lead. They decide how they want to do it, but as they get started, give them some things to consider, such as the experiences of other states. For example, a few embed their municipal and county codes, and if a facility moves, then have to change their codes. Then it no longer becomes a static code. They really need to share that kind of information. It should be a non-meaningful, or "dumb" ID. Anytime you embed any meaning in an ID, you will lose. It will change, and you will obviate the entire purpose of an idea that follows the facility. And EPA can say that to states. You don't have to force it on them, but it would have helped New Jersey five years ago, if EPA had been saying that.

• In order for the Key Identifier to work, you need to get all 50 states to do this. It could be done by policy, by rule-making, or some other means, but the recommendation of this committee has to be that if the Key Identifier is to work, then EPA must have all 50 states willing to do it. Similarly, all EPA programs must be part of this process as well. No fundamental change will come without having all the states and Agency Program Offices buy-in to the process.
• The committee broke at 11:00 a.m. and returned at 11:15 a.m. They decided to forego lunch and work straight through until 1:00 p.m. at which time they would adjourn. At this point discussions continued regarding identification of initial recommendations and issues the committee would need to address in the coming year, in the interim report, and in its final report at the end of FY97. What follows is the result of that discussion, by major topic.

• AA for Information:

• If we are to make a recommendation that the Agency establish an AA for Information, then we must make sure we provide a clear rationale for this recommendation. That function would clearly be much more than just a coordinated CIO function. The creation of such a position would reflect a major shift in Agency mission. If the Agency is going to do what Jack [Dangermond] described as serving customers and using information to do so, and if we're really seeing information as core to a new way that EPA does business, that change or that amplification of its mission is at the heart of our recommendation for everything, and for a Senatorially-confirmed AA for Information. This individual would be much more than just a super bureaucrat who happens to have a little more clout. It would be someone with the confidence of the Administrator, who would carry out a core, Agency-wide, overall mission. Language to that affect would buttress our recommendation.

• Any report should also explain that we view EPA in a wholly different role than it's ever had before. Or, rather, we are envisioning a new role for EPA, which has not be identified before. That concept needs to be understood, up-front, if anyone is to understand where we're coming from.

• The committee should point to some of NACEPT's prior reports, where it clearly indicated that EPA is shifting and expanding it's role. It's becoming one of servicing, and being responsive to communities. That doesn't negate the regulatory side, but it amplifies on it or adds to it.

• Yes. In that we we're indicating that EPA is not doing away with regulation, rather, it's identifying a bold new role. And the only way to really getting it done is to clean up its information systems and assign somebody to do it.

• Technical Assistance Grants (TAG):

• In Denver we heard that, "Education and training programs are needed to teach us how to access the available data resources." That was in the words of the people who were testifying. EPA needs to supply education and training programs to teach citizens how to use available data and resources. Then you can go ahead and say, "Local governments can use their own database professionals, even library people, to help access and organize the information, so the technical people can use them."

• It's an issue of access to resources that the Agency has. It's an issue of timely information going to the communities. It's an issue of communities having an appropriate amount of time to respond and get some of those resources, or have an opportunity to get some of those resources. It's all of those things, and it's the issue of whether the Agency's current process for disseminating the information about grants, whatever types of grants we're talking about (grants as a whole), is really up and running. Is it working or not?

• If you have some kind of regulatory flexibility variance that an industry or facility gets, you need to have certain things. And I hope that we can send this message clearly. You have to have the information to oversee this performance-based reg flexibility initiative, and you need this assistance to the community if you expect to rely on the community for that local oversight.

• The question of trust was raised yesterday. If we're serious about a new, or more flexible, approach to regulation, then there have to be methods in place to verify the trust that's been given. Technical Assistance Grants are one way in which communities and governments can assure themselves that the flexibility given to industry has indeed produced the result.

• If you're talking about some sort of variance, then you're already talking about capital spending, let alone the idea of some sort of community effort. So, the question becomes, "How do you make sure there are resources available to a community so they can understand what's going on?" I don't deny that's a real issue. I see the problem as far bigger than tying it directly, on a one-to-one relationship, between the community and an individual facility. It really becomes an educational problem. Quite often, what it amounts to is that you have a community where the level of education is not as high as we would like to see it...so they don't begin to have the resources within that community to know what some of the resources are that are available to them. What's needed is a general raising of understanding of a whole lot of issues in the community. Certainly, industries in a community have some responsibility, and certainly there are good reasons for them to be involved in helping their community raise that level of understanding. But I don't want to see it tied to a permanent renewal or a permanent variance, because what you're likely to do is stifle the expansion changes in those facilities which may actually only further lead to the problem of stifling those communities. What we're really talking about is a societal problem which goes far beyond one facility that's in a community.

Q: What, then, do you think are the best mechanisms to assure that performance goals are specified in our regulatory flexibility initiative(s)? What is the mechanism to assure that those goals have been achieved? What kinds of information and processes would assure everybody that the results are what they're supposed to be?

• That's a difficult questions to answer, because situations vary from facility to facility. It's impossible to sit here and say, "This is the way to do it..", because it really amounts to -- what amounts to negotiation for the individual [industry] when you look at where they are. It's not a cookie-cutter type approach because you could have two sites that, on the surface, appear to be very similar, but if you actually went into the facilities and looked at them, you might see two generations of newer technology at one site. It has to be a case specific determination. Maybe EPA could do something, not as a TAG grant, but something to teach industry how to work with communities in giving out, or identifying, information.

• Regulatory Flexibility:

• Is there an agreement that, if there's regulatory flexibility, there should be environmental information to monitor the progress of that flexibility? Also, that EPA has a duty to find ways to work with communities and industry to make sure there's a way that information is useful? That EPA has a responsibility to work on those two things?

• I wouldn't tie it to flexibility. I would argue that EPA has responsibility, and the community has a responsibility, to have certain information available. As you increase the amount of flexibility, you're going to increase the transparency of the whole process, and there's going to be more information out there. But it's not a matter of there being no information now and there's suddenly going to be information tomorrow. It's a continual process.

• The main point seems to be that you need information and you need the interpretation of the information.

• But one has to look from a point of view of many communities and not just trust EPA. When you talk about technical assistance or right-to-understand, what you're talking about is technical assistance that's accountable to those stakeholders in that community. So yes, EPA has a responsibility to facilitate this, but EPA also has an interest in seeing facilitated the establishment of independent technical advisors who are accountable to communities. And that's a really difficult thing. It's not something which we find in very many places or in existing law. TAG grants is one place. I can't really think of very many others.

• Maybe some of the language should be very clear in saying that EPA is responsible for providing credible support. And when you say credible, that may mean that in some cases EPA may have to do some independent work. In other cases, it may be simply facilitating the two parties getting together.

• But remember, sometimes we focus too much on EPA. It seems to me that this is often where you get the state role. The state becomes a very important player. And we certainly heard that in Denver. People always seem to believe EPA. They're more likely, though, to turn to their state to find out if they are getting the straight story.

• It strikes me that the reality is there's a continuum. EPA has to be in a position to support this. And it has to work with all the levels so that it's credible. And if that means working with a state, a community, or independently, the Agency's position has to be that it's going to support making it work through the process. In other words, EPA shouldn't be in the way of the process.

• We might want to add a statement regarding grants. EPA, the states, and a lot of us need to make the information infrastructure a viable line item in grants (an expenditure of the grant money). Sometimes grants are very specific on what the money can be spent on, and you have to argue your case for information expenditures (i.e. we argued GIS data development is critical as a planning piece of whatever the overall grant is). Some flexibility on how the recipient can spend that money is required. Can they buy the hardware to get hooked up to Internet? Can they use it to pay their Internet bill, or whatever it happens to be? Somehow those grants need to be more flexible to allow that information infrastructure to be enhanced.

• Grant Notification also needs to be addressed. Notification of grants availability, in a timely manner, is required. Notification should also happen at multiple levels of staffing. In many cases grants notifications go directly to a Tribal Chairperson, and they don't filter down to the rest of the staff until a month later. By that time, we may only have one week to respond. That's much too late.

• And that support could include publishing case studies on how certain industry groups work with communities to publish information that they otherwise wouldn't have made available. So when you support, that means being the true facilitator of that dialog. And facilitation can be direct or indirect. It also can be just information.

• Information Integration:

• It's critical to make the point that there's a long term solution we need to work towards, as well as acknowledging that the transition's going to be difficult and will take some time. We've [New Jersey] been working on it a long time, and we're not there yet. And the transition can be ugly. But that's where you really need to have top level commitment, and you need to try to institutionalize it in some way, so that when, or if, the administration changes and this is not yet accomplished, all that work doesn't go out the window.

• My recommendation would be to redesign and re-architect the entire information system for EPA, and include that which would consider and involve all the various parts of all the various missions. In this way you could respond to all the work flows of the various missions. And one of those missions should be the citizens groups and the public. That's one window into the database. Another window is the various regulatory activities. There would be lots of these windows into the database. And the architecture should be constructed on top of modern platforms (which isn't being done today). Let this architecture be achieved by doing extensive user needs, assessment and prototyping, to ensure that it's done correctly. It should then be reviewed by a committee like this one, in stages over time (perhaps six week targets). Every six weeks there's a review of prototypes and progress. Everybody has a goal every six weeks, and it's all reviewed every six months in terms of overall management progress. And management is involved in it, and stays involved, as if it's as important as any other mission that they support. In other words, buy into the idea that this is mission critical, but it has to be defined to management that it's mission critical. and have it managed as if it's a mission critical component of everything that is done. In fact, it is, but it's just not consciously recognized.

• That's a good idea, but is it realistic that EPA would do that? It would seem that the only way it's reasonable to expect EPA to do this is if they really want to do community-based environmental protection, multi-media reporting, and these other things that require an integrated database. If EPA wants to do that, they've got to do this. If they don't want to do that, they can keep doing what they've been doing and there systems will work without changing anything. It's just evidence that the policy has not changed.

• Much of this is prefatory language to the recommendations. It links the re-architecture, which is the way of achieving all of those changed missions, and sweeps in the transitional steps as well. It's absolutely right. Key identifiers is a means to an end.

• And how do you motivate management to take this bold step? By realizing the way it is now, and the way it isn't now. What is information integration? It's everyone knowing what everyone else is doing. I can accomplish that goal if one department is working with the other departments because of working with common data. So the stages here, and reorganizing EPA from "stove-pipe" areas to a more integrated work activity really won't be achieved by first establishing a common architecture for sharing information and communicating shared information. Then it needs to be followed by the reorganization of work flow and the opening up of possibilities of new, totally new approaches to the way problem-solving is performed ( i.e., placed-based and local government connected with the information providers.) We need to make a good business case of understanding what can't be done with the stove pipe systems, and articulate that well. And I guess what we cannot do very well is interrelate the data so that people can approach the environment the way they should.

• In order to focus this discussion, maybe we should say that we should be working towards One-Stop Reporting and front end integration for existing data collection efforts. It may be that under some of these programs, once you have common units, time frames, and elements that are reported, you can then start combining them. Then that provides the underlying information architecture that you need to simply support permit writers who can report on air and water, together. I think there's a need to state that looking at access alone, people will overlook the limitations of that access, unless we spell out that we need integration efforts in order for the access to be meaningful.

• Actually, One-Stop is the integration of work flow. It's the integration of work. So, it's just as important as the integration of the core data that supports it. And the efforts that are underway to attempt that could be thought about as the ultimate system. Or they could be thought of as a prototype in the staging of full integration. And figuring out the user interface, the way people dialog with integrated water and air, retraining the people to deal with water and air, all of that is also very valuable, and one could conceive of doing that before the integration of the information systems happen. In other words, it's the integration of work with the spider web going out to the different data systems, as opposed to shoving the data systems together and supporting, subsequently, the integration of things. Maybe working both of those sides at the same time is the wiser course to take. Over time, organizations will migrate into the new architecture. But at the same time start to slap together the work activities into an integrated whole. The only thing that management really cares about is the integration of work. And whether it's on five machines or five different systems, they don't really care. If you could really achieve the same integrated work, why would they care. A lot of what we wrestle with, such as the issue of key identifiers, is because it makes possible the integration of the data. which means making possible the integration of work.

• Frankly, key identifiers is not an issue that this committee should be dealing with except that it's forced to have to deal with such a mundane issue because it's recognized that these systems don't work together. It's just too fundamental to database design for it to not have happened by now. So one of the stages should be to reinforce the continuation of things like One-Stop, because they serve as prototyping (even though they're really working systems, but think of it as a prototyping) towards the ultimate integration of the systems.

• Also, if you force one-stop to really occur, no matter what the back office may be doing in the database area, you will force the retraining of people. So. I'd like to make a broad recommendation that we support the efforts of One-Stop, that is the integration of work with technology and training, and so on. But, please don't make the mistake that means integration of the systems, because it does not. It doesn't really mean integration of the database. It's very different worlds and management should understand that. We get these stupid meetings and argue about whether we really should be dealing with common keys. Why should that be an issue? Clever database design should handle all of that, but it's symptomatic of the fact that nobody has ever sat down and built the common keys.

• The problems of data integration are very complex, and they can't all be solved here. The New Jersey experience with integrated permitting is a possible model. It could serve very well as a demonstration of a better integrated working data system.

• Software engineering and systems development is complex in the sense that once you've engineered something, it's not easily re-engineered or changed. For example, GILS was thought out, designed and then somebody sat down and programmed it. GILS was "hard-wired" to do exactly what it does. And we can look at as the user and say, "Well, it ought to just be changed a little bit, drilled down, etc.", and in a way, we all feel that way. Somebody sat down and engineered GILS so it performs in all the engineering trade offs, just as if you were building a car. You just can't take a car off production and say, "Let's move this fender, and do that." You can't do it if it's going to be a really working system. So we need to be careful about what we say, because what the engineers might do is go back and try to re-engineer that whole thing, but only having done it for this one component. So this group has to be aware of the sensitivity about software engineering and what it requires to really pull off anything. It is not simple. That's why everything should be designed by prototyping.

• A good recommendation might be that the CIO have a board of directors, much like organizations that review architecture, over time. A diverse group of representatives from industry, citizen organizations, users of EPA information, etc., should comprise a board of directors (as opposed to a user level). And they should be critical (as we're being critical) of this system to the new architecture and its implementation. They should report to the EPA management, so that it sets up the appropriate checks and balances, so that the CIO doesn't go away and become like the old MIS director in a glass box, or it doesn't become just another turf issue.

• This proposed concept is a good one, because it also gives the CIO a lot more credibility and clout than he might ordinarily have.

• It's about both clout and checks and balances. And an appropriate model is the Science Advisory Board, only this would be the Information Advisory Board.

• Resources:

• If I were the director or the administrator, I'd like to know there's going to be a $50 million investment. And I suspect that probably, at a minimum, it will be. And how can you really do it? For the record, this should be done mostly in-house. It should not be farmed out to some big consulting company.

• EPA is one of the most highly leveraged agencies in the federal government, where IRM is concerned. It has virtually no code written in-house.

• Is there any relationship between the fact that the Agency's architecture is so bad, and the fact that there is no in-house people? Is there any relationship between the fact that there's no staff and organization for IRM and that you have all these sectorial systems? Well, we're saying give them AA. That really means an AA, and a whole staff and department that really takes over the management and reorganization of these systems, instead of just contracting it out piece-meal. By and large, contractors don't give a damn about the information or the organization. Contrast that with some agencies who really treat information as an asset, not as a copy machine. That's a different philosophy.

• There are five secrets of success for integrating a system: (1) A Team of two (one technical and the other management) who work together; (2) Strong, ongoing, management support (which would be acknowledged by the AA and the organization); (3) A strong plan (a real plan....not just someone in position); (4) The plan is totally user-driven (it's not just MIS's plan, but the users' plan. MIS simply figures out how to make it work); and (5) Do the work in-house (it's not done through contractors. You may use contractors, but the system is really owned by a body of people who really care and want to nurture it and make it their life career.) These are the five ingredients for success.

• We shouldn't understate where EPA is with its contractors. EPA, clearly, has people who own systems and would accept ownership of anything developed. That is not contracted out. But contractors perform most of the development in the Agency. Program offices historically had responsibility, from a systems development perspective, for developing and implementing their own systems. As philosophies changed, both politically and organizationally, it became more an outsource. It got to a point, at some stage in the cycle, where virtually everything was outsourced. The in-house knowledge is no longer there, except in a very general way, but then the tide shifts and you really need to go more in-house. And I think that's where the Agency is right now. Most of the systems were developed, in-house, originally, and the argument used to be, if these people die, there's nobody to support these systems, because they're all done in-house.

• I didn't really mean in-house coding, nor avoidance of costs. I really mean system ownership. It has to be conceived, and owned, and loved by somebody. And a contractor isn't it.

• Regarding the point about everything being "user-driven", the idea of a user community is critical. Users inside EPA, by and large, don't care if things are integrated, because they're doing segmented jobs. That's their individual missions. The user who does care, however, is the outside people and states. Regions, more than headquarters, and users in the real world, most of all.

• We should also include the producers of information (the submitters). I would think that one of the goals of a new architecture would be to reduce regulatory burden. Reporting should be made more efficient. Hopefully there would be some cost savings, whether time costs, money costs, costs borne by submitters of information, etc., that we would expect to see in return for the $50 million investment, or whatever it's going to be.

• Keep in mind that EPA people will be users as well. They may not be the ones to driving the decision to integrate the information, but they will be users of it when it's created. Actually, the primary users of the data will be EPA users, because they're the mission-critical mandated users. That's one level. Accept, however, that part of the mandate also needs to be serving citizens. They can be considered secondary users in the design. But your main users are the EPA users, because they're the ones who will pay for the system.

• Ultimately, one of the key issues for EPA is that, as currently organized and currently managed, they are not particularly inclined in that direction. There are a whole series of issues that have to go on in the work process regulation writing in order to create users who are driven to care about this issue.

• This is a case where a small consultant (like two or three people, not a "Big Eight" firm) might be very valuable. They could literally live inside the Agency, but one step removed from the politics, and would be on site as the integration of water and air in a new permit design occurs. The design process would actually be an investigation into the way work is done now, the underpinning of regs, and then document the process. The second phase might be a proposed reshuffling of that work. And then based on that reshuffling of the work, or reshuffling of the work flow, the development of the data model that's necessary to support it. As part of that consideration, one documents the existing data model as it currently exists. In order to create the future, you document the way it is now. Then, based on that new data model, you look at a plan for the actual system architecture, which includes hardware, software, communication, the data model, and the applications. Finally, the last part of the program is really looking at time, dollar, and resource implementation.

• There are a number of people looking at the Agency, such as the Ruckleshouse Committee . They're asking, "Are you organized in a way that will get to this new multi-media mission?" There's a vast amount of discussion about that issue.

• That's the question. The answer is absolutely no. There's your mandate right there: We could never achieve the objectives of the Ruckleshouse Commission unless we totally re-vamp our systems and the way of doing things.

• And that is the discussion that's going on in the Agency. It is the key driver to all this. Why do we have what we have, today? Because, in fact, as an Agency, we are still a regulatory agency, media by media. It reflects policy. That's who we are. And that has to be fundamentally discussed and changed or IRM cannot move in this new direction.
• At this point, the members discussed the next steps to be taken. This dialog resulted in the following:

• The DFO was asked, by the committee, to provide, on-line, a summary of the meeting, so the members could quickly develop a set of preliminary recommendations that would be forwarded to the Deputy Administrator by late-October, 1996.

• A point was made by several members that, if the impact of what the committee produces is to be maintained, then the product would need to be brief and simple. In other words, shorter is better.

• Several members requested an Internet Demo for the next meeting.

• The committee adjourned at 1:00 p.m.

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