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May 5, 1999
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                                                        ROBERT L. RHODES, JR.
                                                        202-457-5943
                                                        Internet Address:
                                                        rrhodes@hklaw.com
Administrator Carol M. Browner
U.S. Environmental Protection Agency
401 M Street, S.W. (Mail Code 1101)
Washington, D.C.  20460

Dear Administrator Browner:

             I am pleased to forward to you the enclosed  Final Report of the
Environmental Information and Public Access Committee (EIPAC), a Committee of
the  National  Advisory  Council for  Environmental  Policy  and  Technology
(NACEPT).

             This report responds to your request that the EIPAC consider Agency
information  policy and infrastructure  issues  and provide  recommendations to
improve Agency decision-making, accountability, and  public access to data.

             The Committee was able to provide the "real-time" advice on public
access initiatives  currently under  way  through the Center for  Environmental
Information  and Statistics (CEIS), including recommendations on how the CEIS
could improve its Web-Site. Those recommendations are included in this Report.
While the Committee was also charged with providing advice on broader Agency
information  policy and infrastructure issues,  shortly  after  the Committee was
launched the Agency announced a major initiative to restructure  its information
management function. As a result, the Committee was asked to defer deliberations
regarding those issues pending completion of the Agency's initiative.

             I hope you will  find this  report  useful as EPA continues to work
toward improved public access to environmental information.  The EIPAC, and the
NACEPT Council  welcome your review and response to their 'work.

                                           Sincerely,

                                           HOLLAND & KNIGHT
                                           Robert L. Rhodes, Jr.
                                           Chair, NACEPT

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NATIONAL ADVISORY COUNCIL FOR ENVIRONMENTAL
       POLICY AND TECHNOLOGY (NACEPT)

   ENVIRONMENTAL INFORMATION AND
   PUBLIC ACCESS COMMITTEE (EIPAC)
              April 1998 - August 1998
         REPORT AND RECOMMENDATIONS
                  April 28, 1999

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  NATIONAL ADVISORY COUNCIL FOR ENVIRONMENTAL POLICY
                       AND TECHNOLOGY (NACEPT)

       ENVIRONMENTAL INFORMATION AND PUBLIC ACCESS
                            COMMITTEE (EIPAC)
                            April 1998-August 1998
                   REPORT AND RECOMMENDATIONS
INTRODUCTION

      The purpose of this report is to document the activities, deliberations, and
recommendations of the 1998 - 1999 National Advisory Council for Environmental Policy and
Technology's (NACEPT) Environmental Information and Public Access Committee (EIPAC).

      The EIPAC evolved from prior information management advisory committees housed
under NACEPT. While each committee over the years assessed a variety of information
management issues, the increasing use of technology within EPA continually created new and
more complex issues, necessitating the value of continued information management assessment
within the NACEPT process. Examples of recommendations submitted to the Agency over the
past 4-5 years from the information committees include:
             strategic  planning for management of EPA's information resources;
             better access to and dissemination of EPA's data and information;
             more and better integration of environmental information;
             development and use of environmental statistics; and
             strengthening the Agency's CIO position, its mission and authority.

      During the tenure of the 1998 Environmental Information and Public Access Committee,
the Agency announced (August 1998) and unfolded (December 1998) a major reorganization
initiative for comprehensive information management. As a result, the Agency's information
managers were focused on reorganization activities. While many of the changes considered by
the Agency were based  on recommendations from prior NACEPT information committees,
EIPAC was encouraged to delay making further recommendations until the reorganization
process was complete. This report is a summary of discussions that took place prior to the
announcement of reorganization.

      The original charge developed for the EIPAC (see Appendix 1) was intentionally broad to
encompass statistical interpretation and uses of data as well as  broad information policy and
infrastructure issues.  The goal was to address information management concepts that would
enhance decision-making, accountability, and public access to data. Some of these issues were
addressed by earlier committees as separate topics. However, there was recognition that
information management is a continually evolving process and that EPA could benefit from the

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broad perspectives of external users of EPA data. These perspectives are invaluable to EPA's
ability to intelligently manage its information and maintain technology relevance.

      Two EIPAC meetings were held prior to the announcement of the comprehensive
information management initiative at EPA. During these meetings, committee members
identified aspects of the charge that could benefit from immediate input from stakeholders. In
addition, the Agency requested the Committee focus its initial efforts on EPA's newly
established Center for Environmental Information and Statistics (CEIS). The EIPAC then
concentrated on:
             goals for CEIS;
             the CEIS customer survey and its results;
           .  access to environmental data and information through CEIS; and
             the relationship of CEIS to the overall Agency information management
             framework and its budget.

       The committee discussed the following issues and developed the recommendations
presented here for the Agency's consideration.
SUMMARY OF DELIBERATIONS

       EPA managers provided committee members with an overview of information
management at EPA and presented several examples of public access and information
management projects. During their initial
discussion of information management
issues, members indicated their hope that
EIPAC recommendations would have
measurable impacts on the Agency and
that EPA would attempt to measure these
effects and subsequently provide feedback
to stakeholders.  EIPAC members also felt
that several of the issues identified during
the presentations were duplication of
subjects  being addressed by other advisory
committees. The committee understood
its role as one "spoke on the wheel" of
many stakeholder groups that  advise the
Agency  (See Information Stakeholder
Wheel).   Therefore, the EIPAC wanted to
 avoid duplication of efforts.
                                            INFORMATION STAKEHOLDER WHEEL
         ENVtRO-
INFORMATIOrqFACTS
AND ACCESS
                REGULATED
                ENTITIES/
                INDUSTRY
        The EIPAC members identified
 three information issues relevant to EPA
 that would benefit from additional stakeholder input. These issues pertain to CEIS and other
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Agency information programs:
             Data Quality
             Public Access and Use
             Intergovernmental Coordination.

       Initially the committee expected to address these issues in separate workgroups.
However the members realized that the issues were very interrelated and relevant for all
members' input.
SUMMARY OF EIPAC ISSUES AND RECOMMENDATIONS

       Issues of both substance (see above) and process (how to effectively advise the Agency)
were of major concern to the members.  In addition, the committee members felt that a dialog
with key senior managers of EPA's IRM offices was essential for effective development of
recommendations for the Agency.
       In response to a request from EPA to address CEIS issues, the Committee examined the
context of CEIS in: a) public access initiatives, b) data suitability, data gaps, data quality, and
c) the overall  management of EPA information and information resources. As a result, the
committee offered the following comments  and recommendations to  CEIS and other IRM
programs:

A.     Public access initiatives:
       The CEIS and other information projects must be sensitive to the need to provide
       information to the public in a variety of media and methods.  Not all segments of society
       have access to computers. CEIS should have available paper documents, videos, ad
       campaigns, etc. - all  of which contribute to providing environmental information to the
       various segments of America's population. CEIS  should consider having state/local
       "branch" offices or partners.

       A review of the CEIS website generated the following comments:
                 A web site and other documents should be provided in other languages,
                 especially Spanish;
                 Distribution of information would be most cost-effective at local levels; a web
                 site should be developed with a centralized, primary source of
                 data/information that could be printed or down loaded at local libraries,
                 universities, labs, etc.
                 The CEIS website address should be added to other web sites for linkages.

       The Committee offered the following goals for CEIS and other public access projects
       within EPA:
                 Enhance  community capacity to participate in environmental decisions;
                 Understand how data are used in decision making - internal to EPA and also
                 to local communities, businesses, and industry who use the data for their
                 decisions on environmental issues and quality;

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                 Increase data use in empowering communities and community
                 development/consensus processes.

B.     Data suitability and data gaps:
       The Committee recommended that:
                 data limitations be explained in various ways to a variety of audiences who
                 may, or may not, be familiar with statistics;
                 IRM planning and management be more centralized to ensure consistent data
                 standards and compatibility with secondary uses;
                 CEIS should take the lead in developing standards and types of data collected.

       The Committee agreed to continue to review the process and findings of the CEIS data
       gaps/suitability study.

C.     CEIS within EPA's overall management of information and information resources:
       The Committee members suggested that CEIS should develop a more detailed and
       organized work plan.  They suggested that the plan include current and proposed budget
       information for each of the CEIS programs. Plans should also include the CEIS budget
       and goals in context with the overall EPA IRM budget and goals.

       The CEIS should develop a 3 - 5 year marketing plan. The plan should address CEIS as
       a "national referral center" of environmental information or a federal "environmental
       information broker." This would help establish its role in managing environmental
       information across and in cooperation with other federal agencies.

       The members repeatedly and strongly suggested the need for consistency across
       information programs and policies. An evaluation of major information projects and
       policies across the Agency would help place the CEIS in context  for its role in the
       Agency.

D.     Other Agency issues:
       The Committee recognized that progress has been made in the Agency in many of these
       areas. But they also felt that efforts made by information management and program staff
       are compromised by a lack of coordination, duplication, and competing or diminishing
       resources. Members voiced the need for the Agency to identify where EPA's various
       IRM functions reside and the organizational design needed to most efficiently manage
       information. Members requested an explanation of the extent of the authority the CIO
       has over agency-wide data policy. They also urged the Agency to continue to elevate
       IRM management issues to senior level managers.

       To better understand EPA's information issues, activities, and approach to  information
 management, the Committee developed the following matrix, with the intent to "fill in the
 blanks" in subsequent EIPAC meetings:
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#
1
2
3
4
5
Issue Area
> Accuracy/
Quality Standards
> Data Integration
> Data Quality &
Redundancies/gaps
* Reporting
Burden/efficiencies
> Examination of
Info collected
> Respond to
Customer Needs
> Diversity of
Dissemination
Regional/State/Local
Roles
Public Involvement/
Process/Policy/
Methodology
Accountability
Mechanisms/
Performance
Measures
Responsible
Office
OIRM/Project
Offices/
Regional
Offices/States




What is
EPA doing?
REI?




What is
Needed?
Accurate
Data/ 100%
current




Recommendations





       The matrix provided a prioritization of IRM issues that the Committee members wanted to
address in subsequent meetings. It also provided an opportunity to identify who within the Agency
is responsible for those issues and activities. The matrix included an area for additional
development of EIPAC recommendations.  Because the work of the EIPAC was curtailed shortly
after this initial matrix was developed, the Committee did not refine the matrix, nor were they able
to add detailed recommendations.

UNFINISHED EIPAC BUSINESS

       The above matrix provides a structure of issues for deliberation by future information
management advisory committees. The Committee strongly feels that ongoing stakeholder
involvement (advisory committees being one mechanism) is essential to improving and maintaining
data quality and public access to EPA's environmental data.

^      The Committee recommends that an ongoing information management advisory committee
        be established to provide advice and recommendations to EPA and its new organization for
        comprehensive information management.
                                          PageS

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            APPENDIX 1
Charge of the Environmental Information
     and Public Access Committee

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                              CHARGE FOR THE 1998
                        ENVIRONMENTAL INFORMATION
                    AND PUBLIC ACCESS COMMITTEE (EIPAC)
                                        of the
          National Advisory Council for Environmental Policy and Technology
BACKGROUND.

       Since 1993, several of NACEPT's committee activities have been focused on EPA
information access and dissemination processes, and on issues directly related to the
development and use of environmental statistics.  Three separate NACEPT committees
(NACEPT IRM Task Force; Ecosystems Information & Assesments Committee;  Information
Impacts Committee) have addressed components of EPA's IRM processes.  Additionally, the
Environmental Statistics Committee of NACEPT has been providing advice to the Agency for
several years on the development, use, and quality of environmental statistics.

       Much of the information management and environmental statistics work produced by
NACEPT has been invaluable to the agency as it developed and implemented an agencywide
IRM strategic plan, Community-Based Environmental Protection (CBEP) strategies, and its new
Center for Environmental Information and Statitistics (CEIS). NACEPT has been instrumental
in providing stakeholder insights and  sound advice as EPA commenced development of these
initiatives and concepts.

       Now that  the IRM strategic planning process, CBEP, and the CEIS have become a
permanent part of the Agency's operations, the need for a different level of stakeholder input
must be defined.  To that end, three of NACEPT's current advisory bodies (IIC, CBEP, ES)
focusing on information management, community-based  environmental protection, and
environmental statistics, should be examined, and where possible, merged.  Similarly, the
charges for these three committees having been met, a new charge should evolve  that more
accurately reflects where EPA is in its information management processes, and brings together
concepts no longer needing to be separately examined and assessed.

CHARGE.

       With the creation of the Center for Environmental Information and Statistics, as well as
with the the implementation of an agencywide IRM strategic plan, EPA is now better positioned
to take a more holistic view of issues  involving environmental information and public access. As
EPA continues development of the tools necessary to support its legislative mandates, as well as
the tools necessary to provide stakeholders  with environmental information that can support their
decision-making processes, various issues need to be addressed. Some of those issues include:

       1.      A holistic approach to information collection, management, dissemination, and
              integration.

       2.      Access to, and validation of environmental statistics.

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      3.      The Long-term role of the Center for Environmental Information & Statistics and
             how it fits within the Agency's current information management model.

      4.      Updating EPA IRM Strategic Plan.

      5.      Public Access to information.

      6.      The Role of the CIO in EPA.

      7.      Implementation of Legislation in EPA (Paperwork Reduction Act; Government
             Performance & Results Act; etc.)

      8.      Effective implementation of Environmental Monitoring for Public Access &
             Community Tracking (BMPACT) within the Agency's information management
             model.

      Although all of the issues identified above are critical, the CEIS is scheduled to open its
doors in January, 1998.  Because of that accelerated schedule, the committee will be asked to
focus its initial efforts on the CEIS (issue #3). Specifically, the members are asked to focus on
the following:

      a.      Examine and provide input regarding the CEIS' long-term goals and objectives.
             Specifically:
             i.      Do they complement the CEIS' Mission & Vision?
             ii.     Are they complete?
             iii.     Are they realistic?

      b.     Address and recommend how the CEIS should fit within the Agency's current
             Information Management Model.
       c.     Address and recommend measures of success for the Center, including:
             i.      Short and long-term milestones
             ii.     Measures of success/progress

       d.     Address and recommend a process to support a continuous stakeholder
             involvement.

       Beyond that initial focus, the committee will be asked to address the other seven issues
identified, and provide recommendations to the agency. The committee, supported and managed
by the Office of Cooperative Environmental Management (OCEM), will work closely with the
Office of Policy, Planning, and Evaluation (OPPE), as well as the Office of Administration and
Resources Management (OARM), in meeting its  charge.  The committee will develop a report
that will be submitted to the Administrator, as well as the Assistant Administrators for OPPE and
OARM, identifying both issues and recommendations.

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              APPENDIX 2

Membership of the Environmental Information
  and Public Access Committee (1998-1999)

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                            Members of the 1998
      National Advisory Council for Environmental Policy and Technology
           Environmental Information and Public Access Committee
             Designated Federal Officer: Ms. Deborah Ross
                                    401 M Street, SW, 1601-F
                                    Washington, DC 20460
Mr. Gerard Bulanowski  (Chair)
Colorado Department of Public Health and Environment
Denver, CO

Dr. Robert Ford
Southern University and A & M College
Baton Rouge, LA

Dr. Michel Gelobter
Rutgers Univiversity
Newark, NJ

Mr. Mark Greenwood
Ropes & Gray
Washington, DC

Mr. Manuel Hernandez
National Hispanic Environmental Council
Riverside, CA

Ms. Patricia Hill
Georgia-Pacific Corporation
Washington, DC

Ms. Linda Hixon
North Chickamauga Creek Conservancy
Chattanooga, TN

Dr. Lois Kaufman
Environmental Research Associates
Princeton, NJ

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Mr. Walter McLeod
American Petroleum Institute
Washington, DC

Dr. Janet Norwood
Urban Institute
Chevy Chase, MD

Mr. Guillermo Rodriguez, Jr.
Latino Issues Forum
San Francisco, CA

Mr. Edward Spar
Council of Professional Associations on Federal  Statistics
Alexandria, VA

Ms. Lori Sundstrom
City of Phoenix
Phoenix, AZ

Ms. Nancy Tosta (Co-Chair)
Puget Sound Regional Council
Seattle, WA

Dr. Linda J. Young
University of Nebraska
Lincoln, NE

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