&EPA
             United States
             Environmental Protection
             Agency
            Office of
            The Administrator
            (1601F)
EPA100-R-98-002
January, 1998
MANAGING INFORMATION
AS A STRATEGIC
RESOURCE:
                     REGIONAL & STATE
                   FEDERAL
               STAKEHOLDERS
            Final Report And
            Recommendations Of The
            Information Impacts Committee
            The National Advisory Council For
            Environmental Policy and
            Technology (NACEPT)

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                                                                   Tom Davis

                                                     Tom Davis Associates, 'LLC.
                                                                381 Lyons Road
                                                       Basking Ridge, NJ 07920
                                                                 908-903-9556
                                   December 18, 1997

CAROLBROWNER
Administrator
US Environmental Protection Agency
EPA A-100
401 M Street SW
Washington, DC 20460

Dear Ms. Browner,

With the concurrence of the Information Impacts Committee of the National Advisory Council on
Environmental Policy and-Technology,  I am pleased to forward to you the final report of the
Committee. The report is based on our original charge to suggest ways to help the Agency
manage information resources and was expanded by Mr. Fred Hansen's subsequent direction
that we review the Agency's strategic information management direction and provide
recommendations  to ensure that the Agency's Information Resources Management direction
supported the Agency's evolving approaches to environmental protection.

That charge was  expanded in April of this year when Mr. Hansen asked us to elaborate on the
advantages accruing to the Agency by implementation of the recommendations and provision of
a vision of success (performance measures), and suggesting timeframes  and strategies which
might be adopted  for implementation.

I would call your attention to the specific recommendations (Section IV) and the model which
we used to discuss the five major recommendations: For each, we detail findings and
background, recommendations, implementation strategies, performance measures, and the
benefits. As you will read, some of the activities suggested have already been implemented and
to the credit of the Agency, there is some level of success to which you  can already point.

It was a pleasure to work with this Committee and the NACEPT staff during the life of the
project. I hope that you will find the report stimulating and useful as you continue to work to
protect the environment. As appropriate, I would be happy to discuss this report and my
experiences with the NACEPT process with you.
                                              Sincerely
                                               lairmar
                                              Information Impacts Committee

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                                       NOTICE
       This report and set of recommendations have been written as part of the activities of the
National Advisory Council for Environmental Policy and Technology (NACEPT), a public
advisory committee providing extramural policy information and advice to the Environmental
Protection Agency's Administrator and other officials of the EPA. The Council is structured to
provide balanced, expert assessment of policy matters related to the effectiveness of the
environmental programs of the United States. This report has not been reviewed for approval by
the EPA and, hence, the contents of this report, and its recommendations, do not necessarily
represent the views and policies of the EPA, nor of other agencies in the Executive Branch of the
federal government, nor does mention of trade names, companies, or commercial products
constitute a recommendation or endorsement for use.

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                                     ABSTRACT
The National Advisory Council for Environmental Policy and Technology (NACEPT) is a public
advisory committee originally chartered on July 7,1988. The Council provides
recommendations and advice to the Administrator and other EPA officials on specific topics
identified by the Administrator and Deputy Administrator.  NACEPT membership includes
senior-level representatives of a wide range of EPA's constituents, including: business and
industry; academia; Federal, State, and local government agencies; Tribal representatives;
environmental groups, and non-profit entities.

In March, 1996, the EPA Administrator requested that a committee of NACEPT be convened to
provide advice and develop recommendations on the Agency's current, and proposed, process for
managing its information resources. This request resulted in the formation of the Information
Impacts Committee (EC) of NACEPT, which was specifically charged with the following:

Review current information requirements and processes, and provide recommendations on how
to effectively position EPA's information resources to support Community-Based Environmental
Protection (CBEP), as well as many of its new long-term initiatives, including the Common
Sense Initiative (CSI); Performance Partnerships; One-Stop Reporting; and Project XL.  The
Committee was specifically asked to address the following:

       •      How should EPA's information resources be focused to effectively address
             Agency, State, local, and Tribal information requirements as CBEP and the new
             Initiatives evolve?
       •      How should current data collections and systems be enhanced to accomplish the
             goals of CBEP and the new Initiatives?
       •      How can information resources make stronger environmental protection
             partnerships?

The committee met several times between April 1996 and September 1997, and the results of
their deliberations can be summarized as follows: If EPA is to succeed in going beyond its
current pollution control-oriented approach to environmental protection, to place-based,
cooperative approaches with its stakeholders, the Agency must:
             Formalize the Use of Information as a Strategic Mission Tool
             Establish Information Policy Leadership and Coordination on an Agency-wide
             Basis
             Integrate Information Across Current Media and Program Divisions
             Provide Broader, More Effective, Public Access to Information
             Assure Ongoing Stakeholder Involvement in Information Policy and
             Management

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee      ,  a         >!   -
January, 1998
                       TABLE OF CONTENTS
EXECUTIVE SUMMARY [[[ E-l

I. INTRODUCTION	,..	....	.1

H. APPROACH ,.	.	............................	 2

IE. OVERALL FINDINGS	4
      A. THE CHALLENGE	, .,	 -, •• 4
      B. INDICATORS OF SUCCESS	 .'•<-..'.. 5

IV. RECOMMENDATIONS ;................................:.......	 8

      Recommendation 1: Formalize the Use of Information as a Strategic Mission Tool	9
            Findings	 9
            Recommendations .........,	9
            Implementation Strategies ............			.	10
            Measures of Success & Implementation Timeframe ....................... 11
            Consequences of Failure to Act	..12
            Benefits of Implementing the Recommendations			 13

      Recommendation 2: Establish Information Policy Leadership and Coordination on an
            Agency-wide Basis	14
            Findings	 14
            Recommendations	 —	15
            Implementation Strategies	 • • • •. • •	• •	 15
            Measures of Success & Implementation Timeframe ...................... 17
            Consequences of Failure to Act	17
            Benefits of Implementing the Recommendations	 18

      Recommendation 3: Integrate Information Across Current Media and Program
            Divisions	, • • • •........... 19
            Findings	 • •	19
            Recommendations	;	,21
            Implementation Strategies	.-:.... -	21

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
             Measures of Success & Implementation Timeframe	23
             Consequences of Failure to Act	.......	 23
             Benefits of Implementing the Recommendations	23
       Recommendation 4: Provide Broader, More Flexible, Public Access to Information ... 24
             Findings	 24
             Recommendations	.25
          .   Implementation Strategies	26
             Measures of Success & Implementation Timeframe	 27
             Consequences of Failure to Act		27
             Benefits of Implementing the Recommendations	 27

       Recommendation 5: Assure Ongoing Stakeholder Involvement in Information Policy
       and Management		... 29
             Findings	 29
             Recommendations	29
             Implementation Strategies	30
             Measures of Success & Implementation Timeframe	 31
             Consequences of Failure to Act	 31
             Benefits of Implementing the Recommendations	 31

ATTACHMENT A — LIST OF COMMITTEE MEMBERS	..	 A-l

ATTACHMENT B — SCHEDULE OF COMMITTEE MEETINGS	 B-l

ATTACHMENT C — SPEAKERS, PRESENTERS & PANELISTS	 C-l
Managing Information as a Strategic Resource:
Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          ""          ^  '
January, 1998
                        EXECUTIVE SUMMARY

In March, 1996, the EPA Administrator requested that a committee of the National Advisory
Council for Environmental Policy & Technology (NACEPT) be convened to review current
information requirements and processes, and provide recommendations on how to effectively
position EPA's information resources to support Community-Based Environmental Protection
(CBEP), as well as many of its new long-term initiatives, including the Common Sense Initiative
(CSI); Performance Partnerships; One-Stop Reporting; and Project XL. The Committee was
specifically asked to address the following:

       •      How should EPA's information resources be focused to effectively address
             Agency, State, local, and Tribal information requirements as CBEP and the new
             Initiatives evolve?
       •      How should current data collections and systems be enhanced to accomplish the
             goals of CBEP and the new Initiatives?
       •      How can information resources make stronger environmental protection
             partnerships?

Between April 1996 and September, 1997, the Information Impacts Committee of NACEPT met
to discuss those issues, and to develop a set of recommendations that would best respond to the
questions posed. As a result of those deliberations, the Committee offered the following
findings:

       •      The Agency is indeed moving toward defining the information needed to support
             its new strategic approaches to environmental protection. It can't develop the
             required information resources, however, unless:

           '•'•*•     EPA successfully establishes information as a strategic mission tool,
              >     The public has information to monitor performance,
              >     Industry has information to develop prevention options,  and
              *•     All stakeholders have the information required for decision-making.

       •      Although Current systems have, for me most part, satisfied regulatory
             requirements for collecting environmental information and managing the single
             media, statute specific programs of the Agency, they were not designed to support
             place-based, multi-media, and cross-media approaches to environmental
             protection or to fully utilize information as a strategic tool.  Current information
             systems do not provide sufficient, appropriate, or accurate information on a multi-
             media basis to:
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
        E-l

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
              *•     Inform decision-making,
              *•     Ensure accountability, or
              *•     Document results and achievements.

Finally, the committee developed five broad recommendations that they firmly believe need to be
implemented if EPA is to succeed in going beyond its current pollution control-oriented approach
to environmental protection, to place-based, cooperative approaches with its stakeholders.  Those
recommendations are:

    •  Formalize the Use of Information as a Strategic Mission Tool
    •  Establish Information Policy Leadership and Coordination on an Agency-wide Basis
    •  Integrate Information Across Current Media and Program Divisions
    •  Provide Broader, More Effective, Public Access to Information
    •  Assure Ongoing Stakeholder Involvement in Information Policy and Management

The Committee firmly believes that by accepting and implementing these five recommendations
for establishing IRM as a strategic tool, EPA will succeed in implementing its new mission
approaches.
Managing Information as a Strategic Resource:
Recommendations to the Administrator
       E-2

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          -/,.         A
January, 1998
                             I. INTRODUCTION

The National Advisory Council for Environmental Policy and Technology's (NACEPT' s)
August 1994 report to the Environmental Protection Agency (EPA) stated that "If EPA does not
change its approach to managing information resources, the Agency will fail to implement its
new guiding principles."1 Since then, the Agency has begun to take significant and important
steps to strategically manage its information resources, such as creating the position of Chief
Information Officer (CIO), initiating the Key Identifiers and One Stop projects, and establishing
the Center for Environmental Information.  There remains, however, much to be done to realize
the full potential of information as a strategic tool in accomplishing the Agency's mission--
protecting human health and the environment.

In April of 1996, EPA's Deputy Administrator charged NACEPT's Information Impacts
Committee (IIC) with reviewing EPA's strategic information management direction and
providing recommendations to ensure that EPA's Information Resources Management (IRM)
direction supports the Agency's evolving approaches to environmental protection.

In January of 1997, the HC presented its Interim Report to EPA.  That report provided
preliminary findings and recommendations encompassing three broad IRM areas: leadership,
organization, and information integration and dissemination.  The Deputy Administrator
responded in a letter dated April 14, 1997, requesting that the IIC expand on its preliminary
findings and recommendations, by further:

   •   Describing the advantages the Agency will derive by implementing the recommendations,
   •   Providing a vision of success (i.e., how will the Agency know it has succeeded in
       implementing the recommendations),
   «   Suggesting strategies the Agency might adopt, and
   •   Specifying a timeframe for implementation.

This report provides the Agency with the committee's final recommendations to further the
Agency's use of information resources as a strategic tool.
       'National Advisory Council for Environmental Policy and Technology, Recommendations for
Comprehensive Information Resources Management (EPA 270-K-94-002). August 1994

Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
                                        January, 1998
                                H. APPROACH

The IIC conducted public meetings, received briefings from EPA staff and discussed information
needs with a wide variety of individuals representing EPA's stakeholders. Additionally, the
Committee conducted several working meetings which resulted in an interim report2 and this
final report.

The HO identified three evolving approaches to environmental protection that it would use as a
basis for developing its recommendations on EPA's IRM strategic direction:
              Place
              Based
           Approaches
Regulatory
 Flexibility
   Cross
  Media
Approaches
These approaches are intended to go
beyond  compliance with pollution
control  regulations  and achieve real
pollution   prevention   and '  source
reduction.  It is the opinion  of the
Committee  that  many  of  these
initiatives  will fail unless industry,
government,  and the  public   have
sufficient   information  to   inform
decision-making,  document  results,
and ensure accountability.

The Committee focused initially but
not exclusively on reviewing  the
strategic direction  of  IRM and  its
ability   to   support   place-based
approaches.  In preparing its final
report, the Committee also considered
the ability of  EPA's information
resources   management to  support
regulatory flexibility and cross-media approaches.
        Why Reform EPA's Information?

  To fully make use of information as a strategic tool, EPA must
  ensure that all stakeholders have sufficient information to:
                      Ensure
                   Accountability
       Information Impacts Committee of NACEPT Interim Report of Recommendations dated January 24, 1997
Managing Information as a Strategic Resource:
Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee         .•.-.."         -;  i
January, 1998
The committee also addressed the questions posed to it by the Deputy Administrator in his memo
responding to the Interim Report. These were:

   V  What advantages will EPA realize by implementing the recommendations?
    •   How will EPA know it has successfully implemented them (what is the "vision of
       success")?
    •   What kinds of strategies could EPA adopt?
    •   Are current EPA initiatives on target?
    •   What timeframe does the committee envision?

Section El, following, discusses the challenges that confront EPA and the Administration as they
attempt to supplement efforts to protect the environment that are based on the current system of
disjointed single-media statutes, with a more cooperative, community-based, active and forward-
looking approach. We also summarize the indicators of success.

The last section of the Committee's report provides its final recommendations. These are based
on the five major recommendations presented in the Interim Report, but they have been
developed further as requested by the Assistant Administrator.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
                                      January, 1998
                        HI. OVERALL FINDINGS
The Committee finds that the Agency is moving toward defining the information needed to
support its new strategic approaches to environmental protection.  However, the Agency cannot
develop the required information resources unless:

    •   EPA successfully establishes information as a strategic mission tool,
    •   The public has information to monitor performance,
    •   Industry has information to develop prevention options, and
    •   All stakeholders have the information required for decision-making.

A. THE CHALLENGE
The Committee finds that EPA's
major programmatic information
systems were designed in an era
when EPA was implementing media-
specific statutes. They were designed
to support pollution control oriented
program-specific data collection and
reporting requirements.  As reporting
requirements evolved thru passage of
various statutes, EPA developed
individual "stovepipe" systems each
of which supported specific program
objectives. The current systems
have, for the most part, satisfied
regulatory requirements for
collecting environmental
information and managing  the
single media, statute specific
programs of the Agency.
Using Comprehensive Approach Designations
To ensure a comprehensive and inclusive review of the
Agency's evolving approaches to environmental
protection, the Information Impacts Committee used the
most generic and fundamental designations for the
approaches they are reviewing. Listed below are some of
the specific EPA projects and initiatives implementing
these approaches.
       Place-Based Approaches
              Community-Based Environmental
              Protection
              Ecosystem Protection
       Regulatory Flexibility
              ProjectXL
              Performance Partnerships
              Common Sense Initiative
              Environmental Leadership Program
       Cross-Media Approaches
              Pollution Prevention
              Environmental Justice
              Environmental Accountability
              One-Stop Reporting
              Facility-Identifier
Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          :           •
January, 1998
EPA's current systems were not designed, however, to support place-based, multi-media, and
cross-media approaches to environmental protection or to fully utilize information as a strategic
tool. Current information systems do not provide sufficient, appropriate, or accurate information
on a multi-media basis to:

   •  Inform decision-making,
   •  Ensure accountability, or
   •  Document results and achievements.

If EPA is to succeed in going beyond its current pollution control-oriented approach to
environmental protection, to place-based, cooperative approaches with its stakeholders, the
Agency must:      ,

   •  Formalize the Use of Information as a Strategic Mission Tool
   •  Establish Information Policy Leadership and Coordination on an Agency-wide Basis
   • , Integrate Information Across Current Media and Program Divisions
   •  Provide Broader, More Effective, Public Access to Information
   •  Assure Ongoing Stakeholder Involvement in Information Policy and Management

The Committee firmly believes that by accepting and implementing these five recommendations
for establishing IRM as a strategic tool, EPA will succeed in implementing its new.mission
approaches.

B.  INDICATORS  OF SUCCESS

The Committee offers the following as indicators/measures of success. EPA will have succeeded
in implementing our recommendations in spirit, as well as fact, if the following indicators/
measures are substantially achieved.

Information Policy Leadership

   •  The Agency should appoint a permanent, full-time CIO, separating the current
      administrative functions, immediately. This position should be comparable to the
      Agency's other senior decision and policy making positions. This recommendation
      should be fully implemented in 6 to 12 months.

   •  The Agency should designate one official to have the authority, responsibility, and
      mission to use information as a strategic resource. (This includes having sufficient
      authority to integrate data and information through a centralized structure or process.)
      This recommendation should be fully implemented in 6 to 12 months.

Managing Information as a Strategic Resource:
Recommendations to the Administrator                                              5

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
       The Agency should make permanent selections for all senior IRM positions currently in
       an acting capacity. Protracted acting positions send a message of indecision and an
       organization in flux.  Permanent selections send the message that the authority for making
       decisions is there. This recommendation should be fully implemented in 6 to 12 months.

       The Agency should increase the effectiveness of the Executive Steering Committee
       (ESC) for IRM, by:

              Clarifying its role and responsibilities, especially to make policy
              Increasing its  authority
              Ensuring ongoing involvement of its principal members, and
              Keeping senior executives informed.

       The Agency should ensure that the ESC has sufficient time for in-depth,  substantial
       deliberation.  This recommendation should be fully implemented in 6 to  12 months.
Data Integration:
       The Agency should develop an implementation plan within 6 months to:
              Develop an initial basic capability to link its databases, by completing the Key
              Identifiers initiative (i.e., Facility ID).  A goal of this effort should be: One stop
              access for the user.
              Integrate all of the Agency's databases. The Agency's ultimate goal should be:
              One integrated database,  reducing duplication of data while maintaining program
              ownership of data.
              Resolve Federal-State barriers to integrating information systems.
Data Accuracy:
       The Agency should develop an implementation plan within 12 months:
              To improve the processes that record data when it is initially submitted by states,
              industry, the public, and other stakeholders.
              To ensure corrections to records submitted to the Agency are processed accurately
              and in a reasonable timeframe (days versus weeks or longer).
              That has the Agency commit immediately to an ultimate goal of achieving an
              integrated information system architecture which ensures that data corrected once
              is propagated to all affected data stores.
              To establish ways to submit and ensure accountability for data corrections.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          >         - 'J\-
January,1998
Public Access;

   •  The Agency should commit immediately to the following actions:
             Reviewing and Selecting Appropriate Public Access Tools
             Establishing a Public Access Program
             Improving WWW Home Page
             Implementing an "800" Number
             Establishing an Information Ombudsman
      -      Providing access to information at alternative locations

Stakeholder Involvement:

   •  The Agency should commit immediately to the following actions:
             Establishing an Environmental Information Users Group (EIUG)
      -      Developing an Effective Means of EIUG Participation in EPA IRM Planning
             Developing Approach/Mechanism for Receiving and Responding to Suggestions
             Developing a Process for Agency Response to All Recommendations of the EIUG
Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
                      IV. RECOMMENDATIONS

 The Committee presents its five major recommendations below, each including an overview of
 findings and a recommended general course of action that EPA should take. These were initially
 presented in our Interim Report. In response to the EPA Deputy Administrator's request, we
 have further expanded on the recommendations. In addition to the findings and
 recommendations, we discuss:

    •   Implementation Strategies which EPA may employ to meet the intent as well as the letter
       of the recommendations,
    •   Recommended Timeframes for implementation (where short-term means 90 days to 1
       year and long-term means up to 3 years),
    •   Consequences of Failure to Act
    •   Benefits of Implementing the Recommendations, and
    •   Indicators of Success, or measures, that will indicate that EPA has implemented the
       recommendations.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         8

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee                    -•;•   -:-
January, 1998
Recommendation 1:
Formalize the Use of Information as a Strategic Mission Tool

Findings

EP A's evolving new approaches to environmental protection will require effective use of
information as a strategic resource. This new approach to the Agency's mission requires
integrated information from across all of the Agency's programs. EPA's current information   '
holdings must be used effectively, and plans to require additional reporting or share information
among government agencies must be carefully planned to inform decision-making, achieve
results, and ensure accountability.

Traditionally, information management has been viewed as a "back room" support function, not
as an integral, equally important part of an organization's resources, nor as a strategic tool for
achieving goals.  The Committee finds that this traditional information management model is
still in existence at EPA. EPA has designed systems to support media-specific, "stovepipe"
regulatory programs (i.e. Air, Water, Pesticides, etc.), each with its own back room IRM support
function. While this model may have been sufficient to support a pollution control approach, it
does not readily lend itself to properly supporting the Agency's evolving new approaches to
environmental protection. Nor is this model sufficient to support the Agency's broader multi-
media goals.

EPA has great difficulty in identifying and inventorying its information resources. There is no
one inventory of data, nor is their one clear data architecture. EPA does not readily know what
data and information it has. Similarly, access to that information is fragmented, without a clear
path identified for users to easily achieve access.

EPA does have some clear examples of how information can be used strategically to support its
emerging approaches. These examples include the Toxic Release Inventory (TRT), EnviroFacts,
and Surf Your Watershed, where information is being provided to all the Agency's constituents to
assist in making informed decisions as they protect their local environment.

Recommendations

EPA must recognize the need to change its current IRM practices if it is to implement the
Committee's recommendations and achieve its own stated goals.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
The Committee recommends that the Agency move to formally establish IRM as a strategic
mission tool. Only then will EPA be able to meet the goals of place-based, cross-media, and
regulatory flexibility to inform decision-making, assure accountability, and achieve results. To
be a strategic mission tool, information management must be officially recognized as a valued
program in the Agency. Further, strategic use of information must become an integral part of the
Agency's normal way of doing business, not merely a support function or a series of separate,
initiatives.  The Committee believes that an organization needs to be established for the sole
purpose of advancing information as a strategic mission tool. Information is the tool that can
help paint a holistic picture of the environmental health of a place, community, or ecosystem; and
it can empower all stakeholders to make more informed environmental decisions. A critical
element of this effort must include EPA assuring more  accurate information, at all levels
(including locational information) for use in analytical, access and dissemination tools.

Implementation Strategies

The Committee offers the following strategies for EPA consideration. While there are many
potential alternative approaches, the following strategies offer a feasible, straight-forward
approach consistent with the intent, as well as the letter, of our recommendations.

Recognize Need To Institutionalize Use of Information  as a Strategic Mission Tool

EPA should issue an immediate statement recognizing the need to change its overall approach to
managing information resources. This policy-level statement should clearly express the Agency's
new vision and direct the efforts of all EPA staff towards achieving it.  Information systems
should inform decision-making, ensure accountability, and document achievements as well as
results.

Reallocate Resources

EPA must commit staff, assign responsibilities, and reallocate resources to this effort. The initial
announcement should be immediately followed by revised delegations of authority to
organizational components, designation of responsible officials, and the necessary budget
documents to reallocate current fiscal year funds, update spending plans, and request funding for
future years.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         10

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          •.'         %
January, 1998
Measures of Success & Implementation Timeframe
:, ' -,' -^ •> .-<££A'i£**'v*"- * * , „ , **-**-
- ~ ^tr ~'^' *,~, V'Actjon x t>«, ;*•*£_./* <
1.0
2.0
3.0
3.1
3.2
3.3
3.31
3.32
3.33
4.0
Recognize Need to Institutionalize Use of Information
as a Strategic Mission Tool.
Commit Staff, Assign Responsibilities, and Reallocate
Resources.
&4. g «-*„ * Jj' » *-
:^ A* - TMeframe^
Immediate
Short-Term
Commit to Changes
Inventory/Architecture for EPA Data
IRM Program with Senior Executives having
Responsibility & Authority to Change Practices
Long Term
ShortTerm
Senior Line Managers take Formal Responsibility
For Their Portion of IRM Program & Commit to
Agency's IRM Program
AA's Institutionalize Agency IRM Issues
AA's Accountable for Meeting Agency's IRM
Secondary Use Goals
Make Part of AA's Performance Agreements
Communities/Public have Integrated & Useful Access
to EPA' s information, including:
o Facility Basics
o Compliance/Permit Information
o Emissions Data
o Decision processes that affect the public (panels,
studies, permits, project start dates, etc.)
o Sufficient documentation to verify reported
information
o CBEP Tools and Case Studies
o EPA Grantmaking Opportunities
o EPA Information Indexes and Directories
Short Term
ShortTerm
ShortTerm
Long Term
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
 Consequences of Failure to Act

 Loss of Leadership Role

 EPA has traditionally been viewed as a key leader, policy-maker, and innovator in the
 environmental community.  Although that is a role EPA believes should be shared with states,
 communities and environmental organizations, EPA is in danger of losing the role altogether.
 EPA still needs to lead at the national level.  But it is being perceived as abrogating more and
 more of that role, especially where information management is concerned. This is especially true
 at the state level, where states are taking the initiative not because they want to, but because they
 must fill the vacuum they perceive in information access, dissemination and management. An
 example is the States of Colorado and Utah, who are bringing geographic information and
 mapping capabilities to the public over the Internet. They are integrating health, science, media,
 and exposure data in ways that are more meaningful to local  communities. Yet, those tools are
 not nationally available.

 EPA also risks losing credibility with all of its stakeholders. Many of them, already frustrated by
 what they believe to be redundant, duplicative, and costly reporting requirements, are skeptical of
 efforts aimed at streamlining reporting requirements, especially since they perceive EPA's IRM
 processes as fragmented.  Industry's belief that no one Agency voice speaks to, and for, IRM
 issues, makes it much more difficult for them to buy in to streamlining efforts.

 Loss of Opportunity to Develop Effective Standards

 Another major risk area is in the development of information standards. Although EPA has
 worked hard to develop information standards, these standards have not been institutionalized.
 Efforts such as Key Identifiers, Data Registry, and others, have been in the "works" for years,
 without formal and complete Agency commitment.  If EPA does not provide strong leadership,
 national standards may never become a reality and the end result may be one standard for each
 state, with the Agency having to grapple with 50 different standards. Stakeholders such as the
 states do not stand still and wait for long. They fill the void perceived and develop tools
 internally. The Committee believes that individual, and conflicting, state standards may begin to
 emerge very soon unless EPA acknowledges its responsibilities and becomes proactive in
 implementing those standards. Development of the necessary standards should be done on an
 agency-wide basis and in conjunction with any corresponding Federal Geographic Data
 Committee (FGDC) activities.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         12

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee          :          :
January, 1998
Benefits of Implementing the Recommendations

Formalizing the use of information as a strategic mission tool will go a long way to providing the
Agency with the structure needed to support its vision of stakeholder empowerment, burden
reduction, streamlining, and "place-based" environmental protection. One IRM voice, speaking
for the Agency, will strengthen its credibility with stakeholders, and will better position the
Agency to succeed as it continues its efforts to:

   •   Streamline environmental reporting for facilities,
   •   Better serve the information needs of secondary users,
   •   Move beyond remediation to pollution prevention, and                      "
   «   Engage all stakeholders in more effective environmental decision-making.
Managing Information as a Strategic Resource:
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
Recommendation 2:
Establish Information Policy Leadership and Coordination on an Agency-wide Basis

Findings

The Committee finds that integrated information — a key tool for the Agency's placed-based,
cross-media, and regulatory flexibility approaches — will not be possible unless one person in the
agency is charged with managing information resources as his/her sole responsibility. The
Committee commends EPA for establishing a CIO prior to enactment of the requirement in the
Information Technology Management Reform Act. The Agency's CIO is charged, however,
with overseeing a vast range of other  administrative responsibilities in addition to managing
information resources.

Insufficient Senior Management Attention to Information

It is the opinion of the Committee that EPA senior management has paid insufficient attention^
the development and use of information as a strategic resource. Keeping the CIO in an "Acting"
capacity, as well as keeping administrative responsibilities as part of the function of that office,
has impeded the institutionalization of the CIO function within EPA.  The CIO's duties and
responsibilities currently share time, attention, and resources with the Agency's administrative
functions. EPA, to this day, lacks a senior manager with>the appropriate authority, and sole
responsibility for managing an effective agency-wide information resources program. There is
still no institutionalized, single point of contact for management of information.

The CIO's policy and authority base has not yet been authoritatively institutionalized in EPA.
The Committee believes that by implementing a strong IRM structure and permanent CIO
position, the Agency will send a message to its constituents, and the public, that it is truly
committed to managing its information and recognizing its importance in promoting effective
environmental protection.

Headquarters Senior IRM Officials' (SIRMOs) Responsibilities Should Be More Uniform,
Consistent, and Authoritative

The Committee finds that the headquarters SIRMOs lack clear, uniform job descriptions and
performance expectations. In too many cases, individuals assigned to that role are, in fact, not
senior managers, and are seldom viewed as the key IRM officials by their respective AA's. The
roles, responsibilities, and levels of authority vary from AA-ship to AA-ship.  Very few SIRMOs
can speak, authoritatively, for their AA-ship, where information management is concerned. Each
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee          5          ;
January, 1998
 Program Office needs to have a clear single point of authority and responsibility regarding their
 IRM policies, plans and technology.

 Recommendations

 The Committee recommends that a new organization headed by a full-time, permanent CIO be
 charged solely with ensuring the delivery and management of the information required to
 accomplish the Agency's mission.  This is essential for ensuring that the Agency will be able to
 move beyond stovepipe systems to provide integrated information for the Agency's new
 approaches. EPA must commit, organizationally, to establishing the appropriate leadership with
 the authority and responsibility for positioning IRM to be the strategic mission tool it should be.

 If the Agency is going to use information to serve a wider range of stakeholders and better
 coordinate programmatic and policy direction, it must establish a focus for Agency leadership.
 EPA must establish an organization lead by someone with the confidence of the Administrator,
 who would carry out a core, Agency-wide mission.

 Implementation Strategies

 The Committee offers the following strategies for EPA consideration. While there are alternative
 approaches, these strategies offer a feasible, straight-forward approach consistent with the intent,
 as well as the letter, of our recommendations.

 Recognize Need to Change IRM Practices

 EPA should develop and issue an immediate statement recognizing the need to change the
 overall approach to managing information resources. This policy-level statement should clearly
 express the new overall vision, direct the efforts of all EPA staff towards achieving the vision,
 and reallocate assignments, responsibilities, and resources.

Demonstrate Commitment to Change

The Committee recommends that EPA's Administrator and Senior Leadership:

   •   Develop an Inventory of Existing Data Resources - Prepare a comprehensive directory
       of operational systems, including basic descriptive information (similar to the Information
       Systems Inventory), contact person, and description of the data the systems contain.
       Provide  specific information on how the data can be accessed.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
       Develop an Overall Information and Data Architecture - Develop a high-level
       information Architecture that would identify the overall types of information which EPA
       currently has, or should have, to meet its overall responsibilities.  The Committee notes
       that EPA's statutory mandates may not authorize it to collect and maintain all of the
       information needed to support its evolving approaches to environmental protection. EPA
       may eventually need to seek Congressional approval.  In addition, EPA should develop a
       Data Architecture in sufficient detail to serve as a guiding resource for systems planners,
       engineers, and developers.

       Implement an IRM Program With Senior Executives Having the Responsibility and
       Authority to Change Practices - EPA should design and implement an overall IRM
       Program that includes effective senior executive involvement. In particular, the
       Executive Steering Committee for IRM charter must be strengthened and expanded. The
       ESC should expand its oversight beyond its own initiatives and projects to include
       planning and oversight to all Agency systems development and enhancement efforts. The
       ESC should be charged with review and approval of plans, oversight of budget, project
       oversight, and overall coordination.

       The membership of the ESC should also reflect its enhanced role. It should be chaired by
       the CIO, and only Committee Principals should have voting and decision-making
       authority.

       Assign the CIO and SIRMOs the Responsibility and Authority to Coordinate IRM
       and Related Initiatives - Under the oversight of the ESC, the CIO and SIRMOs must
       have the responsibility, and authority, to coordinate agencywide IRM and information
       systems efforts on a daily basis. This authority should include being able to require
       status, schedule, and cost reporting by project managers.  They should exercise oversight
       of obligations and spending, review and approve requests for transfers of budgetary
       authority, and regularly inform the ESC of status and progress.

       Ensure Senior Level Decision Makers Take Formal Responsibility for Their Portion
       of the IRM Program - Assistant Administrators must commit to achieving the Agency's
       IRM goals and objectives. Each AA must implement agency-wide IRM policy within
       their own program. Each must be held accountable for meeting agency IRM goals. Each
       AA's Performance Agreement should contain IRM goals and objectives. Finally, each
       AA should actively participate in Agency IRM planning.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee        4;       •":*"-     _____
January, 1998
Measures of Success & Implementation Timeframe
4' «* ^ }^r ^:" Mellon f^- ^.. _, ,'j.C
^4. i ^,-w »*• ^ ™ ^^r j *.,£,„_ i, # j<> j. ^ ^ > 5 y X
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2.0
2.1
2.2
2.3
2.4
2.5
2.6
Recognize Need to Change IRM Practices
- r;'\^feame/; r> ..
Immediate
Demonstrate Commitment to Change
Develop an Inventory of Existing Data Resources
•
Develop an Overall Information and Data
Architecture
Implement an IRM Program with Senior Level
Decision Makers Having the Responsibility and
Authority to Change Practices
Assign the CIO And SIRMOs the
Responsibility and Authority to Coordinate IRM and
Related Initiatives
Senior Line Managers Assigned Formal
Responsibility for Their Portion of the IRM Program
Form the EIUG and Involve at each Stage
Short Term
Long Term
. : •" ' •
Short-Term
Short-Term
Short-Term
Ongoing
Consequences of Failure to Act

The Committee believes that several major consequences will follow a failure to act on the above
recommendations.  Those consequences include:

Failure to Develop an Effective Infrastructure

The Agency will fail to develop and effective IRM policy, planning, and management
infrastructure to support achievement of its goals. While the Agency may be able to pursue a
individual initiatives such as CBEP, Project XL, and Reinvention, it will remain unable to
effectively coordinate or mandate efforts across media and programs. This will result in afailure
to properly coordinate the planning, development, and execution of new systems and databases
across those media and programs, and a failure to effectively provide cross-media information to
the public.
 Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
 Poor Communication

 EPA has publicly committed to implementing initiatives and efforts that will foster cross-media
 and streamlining (CBEP, One-Stop Reporting, Reinvention, etc.) Without the proper
 infrastructure, the Agency may be perceived as unwilling to focus efforts on the real problems of
 information access, dissemination and management. This may, in turn, lead to loss of credibility
 with the Agency's constituents. EPA must be perceived as willing to "Walk the Talk" in building
 a solid foundation for managing information strategically.

 IRM Fragmented

 Without a solid and empowered management infrastructure, the Agency will continue it's
 fragmented approach to managing its information. Stovepipe systems will continue to be viewed
 as the Agency's primary information base, and the inefficiencies and duplicative efforts currently
 plaguing the Agency's IRM process will continue. Reporting and management burdens to the
 Agency, Industries, and the public, will also continue.  And, perhaps most importantly, EPA's
 culture will not change. Information will continue to be seen as a "back room" operation andv
 process.

 Benefits of Implementing the Recommendations

 By implementing this recommendation, EPA will be taking a major step toward establishing an
 effective infrastructure for managing its information resource.  It will assist in establishing a solid
 IRM foundation that can clear the way to:

    •  Institutionalize current and future initiatives into each of the Agency's Program Offices;
    •  Delegate Implementation of initiatives effectively;
    •  Facilitate and increase public confidence in accessing and making use of the Agency's
       information;
   •  Reduce reporting and IRM support burdens; and,
   •  Reduce internal politics/turf protection regarding implementation of IRM efforts.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee                   •
January* 1998
RecommendationS:
Integrate Information Across Current Media and Program Divisions

Findings

Throughout the many dialogs between this Committee and EPA representatives, a clear message
emerged that EPA does not know the full inventory of data it currently has. Existing systems are
not clearly identified, and the Agency's Mormation Systems Inventory is not very accurate, or
complete. Most systems listed are only briefly described, with no detailed description of the
types of information they contain.  Currently, the Agency does not have one integrated,
comprehensive inventory of information that users can go to.

The Committee also found that most data collection efforts in EPA are program and/or media
specific, and most of EPA's systems are maintained on a media-by-media or program-by-
program basis.  Although historically the reasons for these systems'separation by media are
rooted in legislation and other legitimate mandates, the current reality is that very few of these
systems currently lend themselves to integration. Yet EPA's evolving place-based approaches
require integration. EPA has been candid in recognizing that most of its systems cannot easily (if
at all) integrate its information across various media, or by facility, locality, or chemical on an
ongoing operational basis without considerable expense or questionable quality. EnviroFacts is
an example of an initial step to integrate existing information and make it readily accessible to
interested parties, yet this example has required the development of a "front-end" system to bring
data from various systems together and does not truly integrate the data.                       ;

EPA's current information resources are not very well positioned to support the Agency's desire
to go beyond media specific efforts to the more holistic cross-media, community-based efforts.
The Agency's executives and program leadership have only  limited knowledge of the overall
data holdings of the Agency. The Agency's stakeholders have even less knowledge or access to
that information.  The lack of meta data (information about data quality, sources, ownership, etc.)
is a pervasive general weakness of the agency's IRM program. This, coupled with the program
specific nature of EPA systems, makes it very difficult for any interested party to obtain the
information needed from EPA.

In its discussions with both EPA representatives and users at the state, local government, tribal,
industry, and community levels, the Committee also found that EPA currently has-a very poorly
designed data collection process in place. Because the Agency's systems are separated by media
and/or program, those charged with the burden of reporting and/or collecting the data are
increasingly faced with the following issues:
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 Recommendations to the Administrator
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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
        Reporting and Collection Burdens Continue to Increase - Industries and Delegated States
        both complain of increased burden in reporting and collection of data as requirements
        change or increase. This translates to increased costs and hours in fulfilling reporting
        requirements that could be drastically reduced by one means of reporting without
        reducing necessary information for environmental protection.

        Correction of Errors, Across Individual Systems Requiring Like Data, is Virtually
        Impossible - As data is reported, and collected, there exist any number of ways for data to
        be erroneously submitted.  Once an error is stored in one or more of the Agency's
        systems, making corrections to all those systems is an exercise in frustration and futility.
        There is no simple way to ensure corrections are made to all possible systems.

        Facility Identification, Across the Agency's Systems, is Extremely Difficult - Each system
        has its own way of identifying a facility, with no clear way of cross-referencing, or
        uniquely identifying it. EPA's efforts at implementing a Facility Id standard have been
        extremely slow and, to-date, ineffective.

        Data Duplication - To the extent there is data duplication, the current fragmented systems
        make it very difficult to identify duplicative data. It is  a problem EPA needs to address
        quickly.

       Data Processing Costs Continue to Increase on all Sides - Duplicative collection,
        reporting,  and processing of data results in increased costs for all parties. Many industries
        complain of spending increasingly large sums of money and resources to meet all the
       reporting requirements.

       A Complete Facility Picture is Difficult or Impossible to Construct - Because data is
       maintained by individual programs in the Agency, crossing media to compile information
       across system lines is a costly, time-consuming, and virtually impossible task. As
       approaches such as CBEP evolve, and as both the Agency and its constituents continue to
       develop more holistic needs such as watershed status, trends, etc.,  information
       management efforts to support them can be increasingly more costly and ineffective.

       Industry's Environmental Management and Understanding Can Be Fragmented -
       Meeting the Agency's reporting requirements has never been a simple task for industries.
       Individual reporting requirements force industries to review, separately, what they need to
       report and to manage their reporting processes separately.  The current reporting
       requirements do not lend themselves to promoting a more holistic management process
       that would have industries focusing more effort at prevention.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental, Policy and Technology
Information Impacts Committee        ^ v -..     •"''%  -
January, 1998
Recommendations

The Committee recommends that EPA develop an Information Architecture that would address
information needs across media, and other boundaries, in a comprehensive fashion. The Key
Identifiers and One-Stop Reporting Initiatives are a start at making the appropriate connections,
but EPA senior management must act forcefully to move them forward. This will require
partnership with the states and other stakeholders to establish a national facility registry.  EPA's
information holdings must be restructured to permit true data integration and to enable the public
to gain access to it.

EPAshould:                  V
       •      Link existing databases by location and other key identifiers,
       •      Implement One-Stop reporting,
       •      Integrate and reengineer the process of data collection, and
       •      Develop an integrated facility permitting process.

Implementation Strategies

The Committee offers the following suggestions regarding implementation of this alternative:

Establish a Data Architecture

EPA should establish a data architecture as the first critical step to implement this
recommendation. The architecture should focus on integration of data, reduction of duplication
and improved data quality. The architecture should also provide a mechanism to bring issues and
initiatives together.

Integrating information across media, programs, and organizational components will not be an
easy task, but major improvements are possible for relatively modest investments.  The analysis
that will be required should be undertaken promptly, pursued vigorously, and properly provided
with needed resources and management support.  EPA IRM staff must assess the current and
emerging information needs of the various stakeholders groups. This analysis must have the
support of the Agency's highest levels, and must be driven down the Agency's hierarchy as
efforts progress. The analysis must not be allowed to become bogged down in excessive detail,
or delayed by assertions of excessive "uniqueness" by programs or interest groups.

The architecture should be both a "logical" (depicting relationships within the model) and
"physical" (depicting database structure). The logical data model should identify the major

Managing Information as a Strategic Resource:
 Recommendations to the Administrator                                                2

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
 entities (persons, places, or things about which information is being gathered), such as facilities,
 measures of environmental quality, or local jurisdiction, and how those entities relate to each
 other.  The physical model will address the location, structure, access methods and other
 characteristics of the database(s). It should be noted that a logically integrated database, if
 properly thought out, does not need to be physically resident on a single computer, be part of the
 same system, or be managed by the same people.

 The architecture should include a logical and physical data model in which the programs use data
 stored in a core database, not their own isolated databases. For example, the IDEA and
 EnviroFacts databases would be merged. The systems would not change ownership, nor would
 the responsibility for basic data accuracy and integrity. What would change is that the data would
 be standardized, catalogued, reconciled, cleaned up, collected more efficiently and have a more
 standard, less onerous reporting cycle.

 The Administrator should commit the Agency to this effort immediately and the CIO should take
 an active, personal role in directing and managing this effort.

 As a first step, the Agency must develop a comprehensive and realistic Transition Plan. The CIO
 should personally manage the development of the plan, as well as its implementation. EPA
 should also establish a permanent funding base controlled by the ESC, not the IRM staff.  The
 Working Capital Fund may provide a ready mechanism for doing this.

 Establish Key Identifier Standards and Definitions

 An essential first step is to come to closure on, and issue,  the major Key ID standards: facilities,
 organizations, chemicals, and location. The latter two (CAS Number and Latitude/Longitude)
 have been determined, but effort and decision making is needed on the first two. EPA has been
 developing a system that relates facilities to their various identifiers in current systems (the
 Facilities Index System (FINDS)). Full implementation of the facility key identifier initiative
 would result in a major reduction of duplicate facility information at EPA. More importantly,
 users will be able to find out all that EPA knows about a particular facility.

 Promulgate Data Standards

 Once the key ID standards have been established, EPA should promptly disseminate the
 standards to state environmental protection and health agencies, local government agencies,
 industry groups, environmental activist groups, and other interested parties. The standards  should
be published in the Federal Register, posted on EPA's Worldwide Web site, and publicized in
newsletters, journals, and the press.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee        :ir;         :-;.--.
January, 1998
Transition to New Architecture                                      ...-;.-.:..

The Agency must transition quickly to the newly defined target architecture.  Immediate actions
should include:

    •   Development.of accurate meta-data for existing stovepipe systems.
    •   Initiation of projects to develop the target databases,
    •   Development of interim capabilities to cross-reference or merge data from legacy
       systems, pending completion of the development projects, and
    •   Data purification efforts, to ensure that the new systems do not inherit errors.

Measures of Success & Implementation Timeframe
"*A^ ^"^
1.0
2.0
3.0
4.0
>«^^ vf^^-oyr^'; v;r?
Establish Data Architecture
Establish Key Identifier Standards and Definitions
Promulgate Data Standards
Transition to New Architecture
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ft <-. IS «* ^ % W > ^ ^ f ^ ^ -! #fijt.
Long-Term
Short-Term
Short-Term
Long-Term
Consequences of Failure to Act

Failure to implement the recommendations will result in increasing difficulty in EPA achieving
its stated Agency goals and objectives, as well as its IRM vision.

Benefits of Implementing the Recommendations

By implementing the recommendations, EPA will position itself and its stakeholder community
to make major progress towards the new environmental management paradigm.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         23

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
Recommendation 4:
Provide Broader, More Flexible, Public Access to Information	- -'

Findings

The Committee consistently received one message from EPA constituencies: They all need ready
access to information

They all need ready access to information despite their varying degrees of technological
sophistication, abilities, and capabilities. With some citizens and concerned groups lacking
sophisticated computer skills, up-to-date equipment, and, in some cases, even reliable telephone
services, the Committee finds that there are serious access and equity issues inherent in the use of
today's technology and that a range of information access options are needed.

By providing spatial data and analytical tools the Agency is strategically sharing information and
providing a much needed framework for users to analyze the complex relationships within their
communities. Information such as demographics, land use, wetlands, and watershed data support
assessment of a variety of environmental issues including water quality, pollutant loadings and
emergency planning. Despite its initial efforts, the Agency does not yet have sufficiently accurate
information to support spatial analysis on a national basis, without extensive quality assurance
and quality control.

The Committee notes that EPA efforts to improve access to data, while plentiful, have often been
sporadic and incomplete.  Initiatives vie with each other for attention and resources. Many of
EPA's constituents believe EPA has a tendency to pursue the "initiative du jour" approach.

Access to data is often fragmented, convoluted, or both. Those seeking information must first
identify the program office which might be responsible for the data sought. Even then, once the
appropriate office has been identified, the user must track down whoever on the staff knows, in
detail, the system, and how the data can be obtained. The Committee does recognize that EPA
has made major strides in improving access through systems like EnviroFacts and Surf Your
Watershed. But these examples also support our basic finding: the data made available is
collected and made available by individual Agency programs, and is piecemeal. Although efforts
such as these have been positive and useful, an EPA-wide assessment, plan, and action is needed
more. No single, one point of contact currently exists in the Agency to assist users as they try to
identify, and access data and information.

Vigorous and thorough implementation of the Government Information Locator System (GILS)
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee         ,,  .      /?
January, 1998
process is important.  Users seeking access to EPA information should, in principle, have equal
access no matter how they choose, or are able, to communicate with the Agency. Individuals/
Organizations should have the option of receiving data electronically, via telephone, paper, by
mail, or over the counter. Just as EPA's data is fragmented, so also is public access. There is no
single point of contact regarding public access issues, needs, or initiatives.

No one, single manager is in charge of public access processes or assistance. While the CIO may
have an important role, the systems and initiatives supporting access are often not under the
CIO's control; rather, many are program specific initiatives. For example, the data provided via
EnviroFacts is often limited to what programs offer.

Additionally, a structured data quality process does not exist, nor does it provide a suitable means
for correcting inaccurate/incorrect data.  Therefore, EPA risks providing incorrect or outdated
information to its stakeholders.

Public access to information means more than just providing raw data. Recipients of the
information need to know the context of the data and may need assistance in its interpretation.
EPA should provide the information in ways that anticipate, to a degree, the questions which
users are asking.

EPA does not provide adequate meta-data for available data, to users. Meta-data (data about the
data) is needed so that interested parties can assess the usefulness, likely accuracy, time period,
source, and format of the data.

The Committee acknowledges that EPA's recent establishment of a Center for Environmental
Information and Statistics (CEIS) could be a major step in the right direction. If properly
implemented, it could provide a needed focal point and could be used to support the development
of the necessary processes we have identified. The Committee cautions EPA, however, that it
must develop the needed support processes and infrastructure as soon as possible, preferably
before the CEIS opens its doors, if this Center is to be effective.

Recommendations

The Committee recommends that EPA explore all of the various ways in which information
products  can be distributed, including the Worldwide Web, an '800 number' system, libraries
and information centers, and partnerships with state and local government, interest groups, and
others. EPA must recognize the access and equity issues inherent in the use of today's technology
and provide a range of information access options. When providing information, EPA must be
able to cross media boundaries, link data using key identifiers, clearly define and characterize the
information, and appropriately safeguard Privacy Act and proprietary information.

Managing Information as a Strategic Resource:
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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
January, 1998
 Because the Freedom Of .Information Act (FOIA) process is cumbersome and expensive, and
 because there are more effective alternatives available and emerging, it should be considered a
 last resort for providing information.

 Implementation Strategies

 The committee provides the following recommendations for improving access to information:

    •  Review best available tools ~ for searching or requesting information.  EPA should
       select and provide those that are simple, easy to use, and effective.

    •  Provide an electronic link — a link to key information resources can be incorporated in
       EPA's home page. That link should be visible and understandable, and it should be on
       EPA's home page, and placed such that it shows on the computer screen  without having
       to page or scroll down or to the right.

    •  Provide an '800 number' — so that those seeking information have a highly visible,
       publicized first stop. This link should also follow through with  requests, and be
       considered the primary, single point of contact for initial inquiries.

    •  Provide access  to information at alternative locations — such as state offices, other
       federal offices with environmental responsibilities, libraries, schools, community groups,
       or churches, for communities which may lack access to automation.
       •     Provide consistent access — to information regardless of how the information is
             requested (Internet, "800" number, library, community outreach, etc.)
       •     Integrate effective mapping and other visualization tools — including
             software tools, library functions, and user training.
       •     Publish  data in the form  of maps — by making use of emerging Internet
             capabilities.

    •   Provide multi-lingual support — for Citizen Outreach and Environmental Equity
       efforts.

    •   Improve data quality — by providing users with the opportunity to offer corrections to
       data.

The committee also recommends the following strategies for making information more available
to the public:
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 Recommendations to the Administrator
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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee                 ;
January, 1998
   •   Provide information on Pollution Prevention alternative technologies — including
       zero-discharge options and clean-up technologies, organized by industry, chemical, type
       of process, and other relevant categories.

   •   Provide saturation data — the whole human and ecological framework ~ from the
       currently diverse data sources, for communities (including states and other agencies.)
   •   Provide grants information — in a much more timely and flexible manner. Applicants
       for grants should be allowed sufficient time to prepare careful and thoughtful responses.

Measures of Success & Implementation Timeframe
~'~^; *,-;• *\ ,. V-- ; < v*^>''~' ^".
«. «- r--^?^-ViAcf»°n^ ' i^,^ *v, :\
1.0
2.0
2.1
2.2
2.3
3.0
4.0
5.0
Review and Select Tools
^ * ""- ,.,^.,s. .
'; , ^-Timeframe , \. -,'
, ,. > f ^ ^">*^->
Short-Term
Establish Public Access Program
Improve WWW Home Page
Implement "800" Number
Provide access to information at alternative locations
Quality Assurance/Quality Control Program and
Standards established with a feedback loop that works.
Manager of Public Access Established
Get Feedback From Data Users
Short-Term
Short-Term
Long-Term
Long-Tefm
Long-Term
Ongoing
Consequences of Failure to Act

If EPA does not implement this recommendation, it will fail to follow through on the Vision that
has been publicized in its IRM plan. As a second, but still highly important impact will be that
EPA will lose credibility...the public may ultimately perceive EPA as "Talking the Talk" but not
"Walking the Talk".

Benefits of Implementing the Recommendations

Public access to environmental and health information is needed as a major way to achieve the
Administration's goals of reducing reliance on coercive, regulatory, and punitive approaches to
environmental protection, while expanding the role and capabilities of local communities to
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         27

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
assess and protect their "places". Those who live and work in a local community, including
business owners, can not be expected to become effective participants in preventing
environmental problems if, in order to do that, they must become experts in EPA's systems,
invest huge amounts of time and resources searching for information, or can not readily
understand the data accessible to them.

Similarly, the Agency needs to encourage the move towards prevention rather than remediation
by better informing decision-making. All stakeholders need information on the ecological,
economic, and health consequences of their own, and social, decisions. EPA and its partners
must work together to pool the information each has and make it available to all stakeholders to
promote a common understanding of the facts, support a democratic debate on the issues, and
influence environmental decision-making.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         28

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee          :       >
January, 1998
 Recommendations:
 Assure Ongoing Stakeholder Involvement in Information Policy and
 Management                                                        	• - -

 Findings

 The Committee finds that there are new and challenging information issues facing EPA, and the
 Agency needs the help of its stakeholders in addressing them. EPA has a broad range of users of
 its information tools, and it clearly impacts many stakeholders through its policies and
 implementation.  Involvement of stakeholders through NACEPT and other advisory vehicles, as
 well as State representation on the Agency's Executive Steering Committee, have proven useful.
 However, there is no formal, established, and recognized method for ongoing stakeholder
 involvement, beyond the States.

 The Committee points out that mere is no formal forum for stakeholder involvement in EPA
 information management despite new mandates from the Government Performance & Results
 Act (GPRA) to involve interested stakeholders. The Agency should develop such a forum, so
 that all types of users are offered the opportunity to participate. This should be an ongoing body
 and process. Such a body would encourage users to be frank, identify needed actions and
 improvements, and candidly express their views.

 EPA also does not have a feedback loop for public access. Those wishing to comment on how
 data is provided, submit requests, or report problems have no way to provide that information to
 the originators of the data.

 Recommendations

 The Committee recommends that EPA assure ongoing constructive engagement of all
 stakeholders in the development, implementation, and evaluation of new information policies
 and mechanisms.

EPA should establish an on-going information user group, to include representation of major
 stakeholders. This should be open to all current and potential users of EPA information (the
public, regulated industry, state and local governments, public health agencies, etc.) These
constituents must be involved on an ongoing basis. EPA should establish a broad-based
information "Users' Group" to provide regular constructive advice, feedback from stakeholder
constituencies, and reactions to proposed actions and initiatives.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
        29

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
Implementation Strategies

The committee offers the following suggestions regarding the implementation of this
recommendation:

Establish a standing working group'to form the initial core of the stakeholder Users Group. This
working group can be recruited from current active participants in programmatic systems user or
advisory groups, other advisory groups, and members of advisory bodies such as this Committee.
Eventually, EPA can recruit from the stakeholder community, being careful to insure that this
Users Group includes representatives of all types of stakeholders.

The Users Group should be made an effective forum for participation and advice to EPA.  The
Agency should consider various means of supporting them, including:

   •   Worldwide Web home page linked to EPA's, states', industry and other pages.
   •   Lotus Notes discussion database
   •   Supporting a Worldwide Web list server
   •   Publishing a periodic newsletter.

As previously stated, EPA should bear in mind that stakeholders may lack sophisticated
automation and even, at times, basic telephone service.

Finally, if this Users Group is to be helpful to EPA, the Agency must respond promptly to its
recommendations, suggestions, issues, or advice on systems modifications or new development.

As a supplementary recommendation, we observe that EPA should consider investing in, and
supporting, existing information dissemination efforts of other stakeholder groups.  Taking
advantage of what already exists is a means of reducing "duplication, ensuring inclusion of a
broader range of stakeholders, and  becoming an equal partner rather than always being the leader.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         30

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee                   :
January, 1998
Measures of Success & Implementation Timeframe
' ^ '* ; &-' "3 Action * o- <-.--•« ^ - -*~,*\ ""*"
s " ~ \j>- _lv^_'"- « * ' V-* %. -,
1.0
2.0
3.0
3.1
3.2
Establish Stakeholder Environmental Information
Users Group (EIUG)
Involve EIUG in IRM Policy and Planning
S> >, " ^ ^ \ t, •%*« "€.
N „ Timefram^r \ "* •,
•«<. 1 ^v-^'-s^, «v\^,-? ^^, ^
Immediate
Long Term
Respond to all EIUG Suggestions
Develop Approach/Mechanism for Receiving and
Responding to Suggestions
Respond to all EIUG Suggestions
Immediate
Ongoing
Consequences of Failure to Act

If EPA does not implement this recommendation, its credibility with its stakeholders will
continue to suffer, and it will be losing the opportunity to improve efficiency, lower costs, and
expand input from them.

Furthermore, failure to act on this recommendation will deprive EPA, and its stakeholders, the
benefits that would have accrued from an effective advisory body, including:

   •   Improved ability to meet stakeholder information needs,
   •   Improved stakeholder understanding of policies and decisions,
   •   Improved management of information as a resource, and
   •   More accurate data.

Benefits of Implementing the Recommendations

By implementing this recommendation, EPA can expect to benefit from the input stakeholders
can provide. Each perspective is unique. National concerns and perspectives vary from Local
concerns and perspectives, and fronrInternational concerns and perspectives. Each can provide
EPA with insight not readily available within the Agency.
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
         31

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
                                              January, 1998
                                  ATTACHMENT A
                       LIST OF COMMITTEE MEMBERS
Chair: Thomas S. Davis
President & CEO
Thomas Davis & Associates
Murray Hill, New Jersey
. Co-Chair:  Julie K. Norman
 President
 Headwaters Inc.
 Ashland, Oregon
Designated Federal Official:
Joseph A. Sierra
Office of Cooperative
 Environmental Management
U. S. Environmental
Protection  Agency
Washington, DC
Patricia Bauman
President & Co-Director
The Bauman Foundation
Washington, DC
Gerard Bulanowski
Director
Environmental Assessment
Unit
  Colorado Dept. Of Public
Health &Env't
Denver, Colorado

Patricia Cummens
GIS Manager
New Jersey DEP&E
Trenton, New Jersey
Jack Dangermond
President
Environmental Systems
 Research Institute
Redlands, California
 Suzanne M, Hess, AICP/PP
 Supervising Planner
 Hunterdon County Planning
  Board
 Flemington, New Jersey
Patricia K. Hill
Manager
Federal Regulatory Affairs
Georgia-Pacific Corp.
Washington, DC
David Hulse
Associate Professor of
 Landscape Architecture
University of Oregon
Eugene, Oregon

Michael Moilanen
Multi-Media Environmental
Specialist
Mille Lacs Band of Chippewa
Onamia, Minnesota
Cheryl Morton
Senior Manager, Government
 Relations
Synthetic Organic Chemical
 Manufacturers Association
Washington, DC

PaulOrum
Working Group on
Community Right-to-Know
Washington, DC
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
                                                     A-l

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
January, 1998
                             ATTACHMENT B
                 SCHEDULE OF COMMITTEE MEETINGS


                             PATES & LOCATION

                     April 17-18,1996   -    Arlington, Virginia

                     July 11-12, 1996    -    Denver, Colorado

                     September 10-11,1996 - Washington, DC

                     January 21-22, 1997  -  Washington, DC

                     April 15-16,1997    -   Washington, DC
Managing Information as a Strategic Resource:
Recommendations to the Administrator
       B-l

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 National Advisory Council for Environmental Policy and Technology
 Information Impacts Committee
                                                         January, 1998
                                  ATTACHMENT C
                       SPEAKERS, PRESENTERS & PANELISTS
 COMMUNITY:

 BethGallegos
 Lorraine Granado
 Mary Miera
Chairperson, Citizens Against Contamination, Denver, CO
Director, Cross Community Coalition, Denver, CO
New West Side Economic Dev. Corp., Lincoln Park/La Alma, Denver, CO
LOCAL GOVERNMENT:
Dr. Ed Demos
Guillermo DeHerrera
R. L.Jones
DaveSwanson
STATE:
Jim Christensen
Deborah Myers

Dr. Florine Raitano

TRIBAL:

Kim Clausen
Debbie Madison
Wes Martel

INDUSTRY.

Frank Gorski
Mark Greenwood
Rex Tingle
Bilinda Townsend
Allen White
Denver Environmental Services, Denver, CO
Commissioner, Adams County, Colorado
Clear Creek Superfund Site TAG, CO
Pollution Prevention Program Manager, Boulder County Health Department,
Boulder, CO
Environmental Scientist, Utah Division of Water Quality
Senior Environmental Analyst for Inspection and Compliance
Wyoming Department of Environmental Quality
Executive Director, Colorado Rural Development Council
Environmental Specialist for Oglala Souix Tribe
Environmental Manager, Fort Peck Tribe, Montana
Wind River Associates, Wyoming
Huntsman Polypropylene, Woodbury, NJ
Coalition for Effective Environmental Information (CEEI)
Industrial Hygienist/Labor Representative, AFL-CIO
Federal Environmental & Health Affairs, Boeing
The Tellus Institute
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
                                                                C-l

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National Advisory Council for Environmental Policy and Technology
Information Impacts Committee
                                                       January, 1998
                                 ATTACHMENT C
                  SPEAKERS, PRESENTERS & PANELISTS
                                      (continued)
EPA-REGIONAL:

Josie Hernandez       Data Systems Leader, Pollution Prevention Office, Region VIH
Robert Laidlaw        Director, Region Vffl Environmental Service Center & Technical Library
Nathaniel "Nat" Miullo Community Environmental Protection Coordinator, Region VET
PaulReiderer         Dkector, Data Systems Management, Region VIE
Lee Roberts          Tribal Program Manager, Tribal Assistance Program, Region VIE

EPA - HEADQUARTERS:
Dr. Allan Abramson
Marian Cody
Dave Davis
Mark A. Day
Elizabeth Fellows
Patrick J. Garvey
Edward J. Hanley
Clarence Hardy
Jim Home
Antonio Jover
Jacques Kapuscinski
Jon Kessler
Arthur Koines
David Lyons
Emma McNamara
MikeMundell
Alvin M. Pesachowitz
Kathy A. Petruccelli
Michael Stahl
Tom Tillman
Paul A. Wohlleben
Dkector, Information Management Division, OPPT
Special Assistant to the Deputy Administrator, EPA
Deputy Director, Office of Wetlands, Oceans & Watersheds, OW
Director, Information Resources Management Planning Division, OERM
Chief, Monitoring Branch, AWPD, OWOW, OW
Team Leader, Information Warehouse, OIRM
Dkector, One Stop Reporting
Dkector, Office of Cooperative Environmental Management, OA
Office of Wastewater Management, OW
Senior Information Resource Management Official, OSWER
Project Leader, CBEP Page & Tool Kit
Dkector, Emerging Sectors & Strategies Division, OPPE
Deputy Dkector, Office of Strategic Planning & Envkonmental Data, OPPE
Chief, Energy & Transportaion Branch, OECA
Team Leader, Information Access Team, OIRM
System Manager, Permit Compliance System
Acting Assistant Administrator, OARM
Acting Deputy Dkector, OIRM
Deputy Assistant Administrator, OECA
Chief, Communications & Outreach Branch, OPPTS
Acting Dkector, OIRM
Managing Information as a Strategic Resource:
 Recommendations to the Administrator
                                                               C-2

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