United States
Environmental Protection
Agency
Administration And
Resources Management
(PM-211D)
220 B-92-008
March 1992
Locational Data Policy
Implementation Guidance
Guide To The Policy
Printed on recycled paper
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TABLE OF CONTENTS
EXECUTIVE SUMMARY [[[ ii-1
Chapter 1 INTRODUCTION [[[ 1-1
1.1 Purpose cfLocational Data Policy [[[ 1-1
1.1.1 Policy Requirements [[[ 1-1
1.1.2 Policy Benefits [[[ 1-1
1.1.3 Scope of Participation [[[ 1-2
1.1.4 Locational Accuracy Task Force [[[ 1-2
1.2 Background [[[ 1-2
1.2.1 Motivation for Policy Development [[[ 1-3
1.2.2 Concurrent Federal Agency Data Requirements [[[ 1-3
1.3 Contents of This Guidance Document [[[ 1-4
Chapter! REQUIREMENTS [[[ .. ......................................... 2-1
2.1 Applicability and Scope [[[ 2-1
2.1.1 Data Types Affected by the LDP [[[ 2-1
2.1.2 Entities under the Scope of the LDP [[[ 2-3
2.1.3 Data Collection Activities Affected by the LDP [[[ 2-4
2.2 Required Locational Data [[[ 2-6
2.2.1 Latitude [[[ 2-6
2.2.2 Longitude [[[ 2-7
2.2.3 Method [[[ .....2-8
2.2.4 Accuracy [[[ 2-9
2.2.5 Description [[[ 2-13
2.3 Recommended Locational Data [[[ . ........... 2-13
2.4 Special Considerations [[[ 2-13
2.4.1 "Tiering" and Spatial Extent [[[ 2-13
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TABLE OF CONTENTS (continued)
4.3 Other EPA Offices and Programs 4-7
4.3.1 Non-Media Program Office Responsibilities 4-9
4.3.2 Media Program Offices 4-15
4.3.3 Individuals/Functions 4-17
4.4 State, Indian Tribe, and Trust Territory Delegates........................ 4-20
4.4.1 Variability of State LDP Responsibilities under Different Types of Federal
Environmental Laws 4-20
4.4.2 Reporting Requirements 4-22
4.4.3 EPA Support to States for LDP Participation. .....4-23
4.5 Designated Representatives , 4-24
Chapters AGENCY-WIDE SCHEDULE 5-1
5.1 Schedule and Priorities 5-1
5.1.1 Accuracy Goal 5-1
5.1.2 LDP Implementation Plans 5-1
5.1.3 Existing and Planned Systems 5-3
5.1.4 Historical Data 5-4
5.1.5 Form and Contract (Tool) Modifications 5-4
5.1.6 Role of FINDS 5-5
5.2 Coordination with Other Federal Agencies 5-6
5.2.1 Office of Management and Budget (OMB) 5-6
5.2.2 Federal Geographic Data Committee (FGDC) 5-6
5.2.3 Federal Geodetic Control Committee (FGCC) 5-7
Chapter 6 LDP IMPLEMENTATION PLANS FOR PROGRAMS
AND ENVIRONMENTAL IMTIATTVES.............................................. 6-1
6.1 Components of LDP Implementation Plans 6-2
6.1.1 IdentiHcation of Entities to Which the LDP Applies 6-2
6.1.2 Definition of Activities During Which LDP Data Will Be Collected 6-3
6.1.3 Enhancements to Data Bases and Systems 6-3
6.1.4 Tool Redevelopment for Collecting and Documenting Locational
Data 6-5
6.1.5 The Format of LDP-Required Data 6-9
6.1.6 Identification of Methods to be Employed 6-9
6.1.7 Definition of Roles and Responsibilities 6-7
6.1.8 Resources/Priorities 6-11
6.1.9 Quality Assurance Measures 6-12
6.1.10 Constraints 6-12
6.1.11 State Roles and Responsibilities 6-12
6.2 Process for the Developing LDP Implementation Plans , 6-13
6.2.1 Coordination of Steps to Achieve 6-13
6.2.2 Phasing 6-13
Chapter 7 DATA CONVERSION AND COLLECTION METHODS 7-1
7.1 Centralized vs. Incremental Data Conversion and Collection 7-1
7.2 Locational Data Conversion Methods 7-2
7.2.1 Conversion from Non-Coordinate Geopolitical Locational
Information to Latitude/Longitude 7-2
7.2.2 Conversion from One Coordinate System to Another 7-7
7.2.3 Conversion from One Datum to Another. 7-8
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TABLE OF CONTENTS (continued)
7.2.4 Guidelines on How to Choose a Locational Data Conversion Method 7-9
7.3 Locational Data Collection Methods 7-10
7.3.1 Conventional Surveying 7-13
7.3.2 Map Interpolation 7-13
7.3.3 Photo Interpretation 7-15
7.3.4 LORAN-C 7-16
7.3.5 Global Positioning System (GPS) 7-18
7.3.6 Hybrid Systems 7-20
7.3.7 Guidelines on How to Choose a Locational Data Collection Method 7-20
Chapters SYSTEM IMPLICATIONS 8-1
8.1 Locational Data Management. 8-1
8.1.1 Relationship Between LDP Data Elements 8-1
8.1.2 Structure and Format of LDP Data Elements 8-2
8.1.3 Position and Function of Location Identification Data -8-4
8.1.4 Relationship to Other Locational Data 8-5
8.1.5 Edit Checks 8-5
83. Locational Data Sharing 8-6
8.2.1 State Entry in FINDS 8-6
8.2.2 GRIDS 8-6
8.2.3 National Spatial Data Transfer Standard 8-7
APPENDIX A - Locational Data Policy and LATF Recommendations A-l
APPENDDC B - Contacts for LDP Implementation Assistance....................................... B-l
APPENDIX C - Partial List of Forms Relevant to LDP.........~................................................. C-l
APPENDDC D - Facility Definition Guidance from the Facility Identification Data
Standard Implementation Plan (FIDSIP) D-l
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LIST OF EXHIBITS
Exhibit 2-1
Exhibit 2-2
Exhibit 2-3
Exhibit 4-1
Exhibit 4-2
Exhibit 4-3
Exhibit 4-4
inhibit 4-5
Exhibit 4-6
Exhibit 5-1
Exhibit 6-1
Exhibit 6-2
Exhibit 6-3
Exhibit 7-1
Exhibit 7-2
Exhibit 7-3
Exhibit 7-4
Codes to Document Method 2-9
Concept of Precision vs. Accuracy 2-11
Relationship of Method, Description, and Accuracy to
Lat/Long Coordinates 2-16
OIRM Organizational Chart 4-3
OIRM Reponsibilities under the Locational Data Policy 4-4
EPA Office and Program Responsibilities under the Locational
Data Policy 4-8
Interaction between the Regional GIS Work Group and the GIS User
Community 4-12
Components, Goals, and Objectives of the Regional GIS Work Group
Strategic Plan 4-14
Individual Responsibilities under the Locational Data Policy 4-18
Agency-wide LDP Implementation Schedule 5-2
LDP Implementation Plan Summary 6-4
Example of Table of Contents for LDP Implementation Plan 6-6
Review of the 637 Forms in the EPA Forms Catalog 6-10
Incremental vs. Centralized Data Converion and Collection 7-3
Comparison of Locational Data Conversion Methods 7-4
Comparison of Locational Data Collection Methods 7-11
Cost vs. Accuracy Curves for Collection Methods 7-12
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Preface
This draft of the Locational Data Policy Implementation Guidance - Guide to the
Policy (February 1992) reflects the many suggestions received in response to a prior
version dated February 1991. The major change from that pre-draft version to this
version is the incorporation of review comments from members of the Agency's
Locational Accuracy Task Force and EPA's IRM community.
Support for development of both drafts was provided by Booz-Allen & Hamilton
Inc. under EPA contract #68-W9-0037, Delivery Orders #046 and #094.
Comments on this draft document should be submitted to OIRM to be considered
for inclusion in the next version. Any comments or questions on this draft should
be directed to:
Jeff Sabol, Program Manager for Data Administration
Information Management Branch (PM-211D)
Information Management & Services Division
Office of Information Resources Management
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Phone: (202/FTS) 260-8974
Fax: (202/FTS) 260-3923
EPA email: Sabol.J
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Executive Summary
'Background
The Locational Data Policy (LDP) was made effective on 17 May 1990 when, after
formal Agency-wide review, it became an official directive under the 2100 series and
Chapter 13 of the EPA Information Resources Management Policy Manual. The
purpose of the LDP is to ensure the collection and documentation of accurate,
consistently-formatted, fully-documented, latitude/longitude (lat/long) coordinates
as part of all spatially-relevant data gathering activities. Under this policy, collection
and documentation of locational information will be performed for all facilities,
sites, monitoring points, and observation points regulated or tracked by EPA under
Federal environmental laws. In addition to lat/long coordinates, the LDP requires
documentation of specific information regarding the method used to measure
lat/long, the accuracy of the measurement, and a description of the entity that the
lat/longs represent.
Other notable points are as follows:
All Agency-sponsored data collections and activities that
define/describe attributes (environmental characteristics) about a place
are within the scope of the LDP.
As an established Agency-wide goal for new data, coordinate points are
to be accurate to within 25 meters.
The LDP establishes a technology-based standard (i.e., lat/long
coordinates should be obtained from the best practicable geocoding
technology).
Due to its potential for yielding consistent, highly accurate measurements, the
Agency currently considers Global Positioning Systems (GPS) to be the best
practicable technology. With implementation of the full constellation of GPS
satellites scheduled for completion in 1992, and with the proliferation of
commercial measuring devices, GPS should serve as the method of choice until a
more accurate or less expensive technology (with similar accuracy) is introduced.
Policy Implementation Guidance
Locational Data Policy Implementation Guidance is provided in four documents:
the Guide to the Policy, (i.e., this document) the Guide to Selecting
Latitude/Longitude Collection Methods, the GPS Primer, and the Summary of
Comments on the February 1991 Guide to the Policy. The Guide to the Policy
explains the basic collection and documentation requirements of the LDP and the
Agency-wide steps for its implementation. The Guide to Selecting
Latitude/Longitude Collection Methods provides cost and accuracy estimates for
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several common geocoding methods. It also offers procedures for selecting a
geocoding method and for estimating resource requirements. The GPS Primer
provides instructions on how to optimally apply GPS technology. The Comments
Summary presents the comments that were received regarding a prior draft of the
Guide to the Policy, upon which this version is based.
Policy Specifications
This Guide to the Policy provides specifications for collection and documentation of
all information relevant to EPA's locational data policy:
Complete locational data include lat/long coordinates, method,
accuracy, and description. Documentation of lat/long, method, and
accuracy have prescribed formats; description is free-format.
Measurement technology, datum, and scale (if applicable) should be
documented as part of "method" information; North American Datum
(NAD) 1983 should be used at this time; GPS is the preferred
technology.
Accuracy should be 25m or better for all new data collected after
12/31/91 and all existing data by 12/31/95, and GPS should be phased in
for wide-scale use by 12/31/95.
Locational data should correspond to the tier (entity of environmental
concern) for which attribute data are collected.
The dimensional quality of locational data (i.e., points, lines, or
polygons) should be determined by the use of the data and the scale of
the map or analysis.
Date of collection and source of locational data (i.e., who collected it)
should be (but is not required to be) documented in addition to
lat/long, method, description, and accuracy.
The Locational Accuracy Task Force (LATF)
The LATF was created in 1990 to assess the Agency's need for a minimum accuracy
requirement as part of the LDP. The LATF presented its recommendations to the
IRM Steering Committee in December of 1990, stating that:
All Agency locational data should be accurate to within 25m by the end
of 1995
The best practicable geocoding technology, currently GPS, be phased in.
for wide-scale use
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A program of incentives be applied to encourage states and the
regulated community to comply with the LDP
EPA's Facility INDex System (FINDS) should be enhanced and used as
a functional repository of locational data for regulated facilities
A program of waiver applications from LDP requirements should be
established for approval by EPA's IRM Steering Committee.
These recommendations were endorsed by the EPA Deputy Administrator and
were incorporated into the 1991 revision of Locational Data Policy.
Roles and Responsibilities
Responsibilities for implementing the LDP are shared by many groups. A general
template for activities is as follows:
The IRM Steering Committee will oversee Agency-wide LDP adoption
and evaluate any requests for LDP waivers.
OIRM will provide information resources, policies, and
implementation guidance.
ORD will evaluate technological developments and provide DQO
guidance.
OPPE will provide assistance to programs where LDP-required data are
collected from the regulated community.
Managers of program offices and environmental initiatives will
prepare LDP Implementation Plans and institute procedures within
their programs (including delegated states) to assure LDP requirements
are met.
EPA regional offices and their state counterparts will be key players in
implementing the policy by ensuring that LDP requirements are followed in the
field. State, Tribal, and Trust Territory delegates and EPA-agents are subject to the
same requirements as EPA program offices.
LDP Implementation Plans
Each program office or environmental initiative should complete a comprehensive
LDP implementation plan that addresses the numbers and types of entities to which
the LDP applies; the tools to be used for measuring and documenting locational
data; definitions of priorities and resource allocations; quality control measures; and
organizational roles and responsibilities. Data Quality Objective (DQO) reports are a
valuable tool that can be used for program planning and waiver application, if
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necessary. The IRM Steering Committee will monitor the development of all
program LDP implementation plans and evaluate waiver requests based primarily
on justifications demonstrated in the DQOs.
Agency-Wide LDP Implementation Steps and Schedule
Although the Policy Guidance specifies that full LDP implementation will be
complete by December 31, 1995, all newly generated data collections should comply
with the LDP from this point forward. As for existing data collections, general
priorities have been established for bringing data into compliance with LPD
requirements. Highest in priority are data collections with geographic coordinates
other than lat/long (e.g., UTM and/or state-system coordinates). These data can be
converted to the lat/long system using common algorithms. Of second priority are
data collections with lat/long coordinates but without the required metadata
(method, accuracy, and description). Of third priority are data collections with no
geographic coordinate data or metadata. Although data collectors have flexibility to
chose other implementation priorities based on their requirements or
organizational processes, a// Agency locational data is expected to be in compliance
with LDP requirements by the end of 1995.
LDP Implementation Plans are to be completed and submitted to the IRM Steering
Committee for review by June, 1992. Final approval should be targeted for
September, 1992. Data collection should be accomplished by map interpolation
beginning in 1992 and phased out as GPS becomes more available. Use of GPS
should be widespread by the end of 1995. Collection and documentation tools (e.g.,
survey or permit application forms) should modified by March, 1993 to ensure LDP
data are obtained in the course of normal field operations. Computer system
enhancements for storing and accessing locational data should be planned for in
1992 and any redesigns should be completed by December 1995.
Methods of Locational Data Collection
This Guide to the Policy provides descriptions of a variety of methods used for
collecting and converting locational data. These methods include address matching,
map interpolation, LORAN-C, photo interpolation, surveying, and GPS (which
should be used whenever possible, and phased in for wide-scale use by the end of
1995). For comparative purposes, each method is presented in terms of
needed/anticipated expertise, effort, cost, and accuracy. The Guide to Selecting
Latitude/Longitude Collection Methods also provides details on the various
methods and on the procedures to follow for choosing a method and estimating
resource requirements. The GPS Primer provides technical information on the use
of GPS technology.
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System Implications
Because the LDP affects an extensive number of Agency data collections, this
document also offers general guidance for handling locational data in computer
systems. The policy requires four pieces of information, as follows:
Lat/long coordinates are a repeating set of numeric fields (two separate
fields).
Method is set of three separate, coded, alphanumeric fields identifying
measurement technology, datum, and scale of map (if applicable).
Accuracy is presented as a range of lat/long units (e.g., +/- degrees,
minutes, or seconds).
Description is a free-format, text field with specifications for the type of
data to include.
In addition to containing the above data elements, it is highly recommended that
cL.a bases include information on the date of collection and source of data (e.g., EPA
office, state organization, contractor, etc.). Computer systems with environmental
data should offer users full capabilities to search through and select records based on
any or all locational data elements. Edit checks for locational data are
recommended. To facilitate LDP implementation, OIRM is working on providing
general locational coordinates for all the facilities in the Facility INDex System
(FINDS).
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:->>W-:w-w>w^
Chapter 1
INTRODUCTION
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1. INTRODUCTION
Guidance for implementing the U.S. Environmental Protection Agency's Locational
Data Policy (LDP) throughout the Agency and applicable regulated community is
provided in a series of four documents produced by the Office of Information
Resources Management (OIRM). These documents include the Guide to the Policy,
(i.e., this document) the Guide to Selecting Latitude/Longitude Collection Methods,
the GPS Primer, and the Summary of Comments on the February 1991 Guide to the
Policy. The Guide to the Policy explains the basic collection and documentation
requirements of the LDP and the Agency-wide steps for its implementation. The
Guide to Selecting Latitude/Longitude Collection Methods provides cost and
accuracy estimates for several common geocoding methods. It also offers procedures
for selecting a geocoding method and for estimating resource requirements. The
GPS Primer provides instructions on how to optimally apply GPS technology. The
Comments Summary presents the comments that were received regarding a prior
draft of the Guide to the Policy, upon which this version is based.
1.1 Purpose of the Locational Data Policy
The primary purpose of the Locational Data Policy is to ensure the collection of
accurate, consistently-formatted, fully-documented locational coordinates for
facilities, sites, monitoring points, and observation points regulated or tracked
under Federal environmental programs within the jurisdiction of the U.S.
Environmental Protection Agency (EPA). The intent of the policy is to allow data to
be integrated based upon location, thereby promoting enhanced use of EPA's
extensive data resources for cross-media environmental analyses and management
decisions pursuant to the Agency's mission to protect human health and the
environment. The objective of this policy is to improve the overall quality and
compatibility of locational data throughout EPA.
1.1.1 Policy Requirements
The Locational Data Policy establishes principles for collecting and
documenting geodetic coordinates defined in terms of latitude and longitude
(lat/long). In addition to these locational data, the LDP requires
documentation of specific information regarding the method used to
measure lat/long coordinates, the accuracy of the measurement, and a
description of the place where the lat/longs were taken. Further, the LDP
commits OIRM to develop policy implementation guidance. This document,
and its set of companions, fulfills that commitment.
1.1.2 Policy Benefits
Independent data collections can be integrated based upon location only after
each set contains consistently-formatted, locational coordinate data of an
expected or known level of quality. The capability to integrate data will
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enhance the utility of EPA's extensive data resources for secondary
applications, such as cross-media analyses and decision-making. Known-
quality locational data also will bolster the Agency's development of
environmental risk management and pollution prevention strategies,
methodologies, and assessments. In short, the ability to integrate data based
upon location will increase the return on EPA's significant data investments.
1.1.3 Scope of Participation
This policy applies to all EPA organizations and agents, including state and
local government personnel, directly responsible for, or who have delegated
authority for, implementing Federal environmental laws. The policy applies
to all organizations with responsibilities to support EPA, including
contractors, universities, and grantees who design, develop, compile, operate,
or maintain EPA information developed for environmental program
support. Certain requirements of this policy apply to existing as well as new
data collections.
In some instances, deviations (i.e., waivers) from specific requirements of this
policy may be justified. Applications for waivers will be made to the ERM
Steering Committee who will review the applications and grant or deny such
requests.
1.1.4 Locational Accuracy Task Force (LAID
Under the auspices of EPA's IRM Steering Committee, EPA and participating
states (including Indiana, Minnesota, and Oregon) created the Locational
Accuracy Task Force (LATF) to assess the Agency' need for a minimum
accuracy requirement in the LDP. The LATF presented its final
recommendations to the Steering Committee in December 1990. The
recommendations of the LATF form a key component of the official Agency
policy and guidance relating to locational identification for environmental
data. The recommendations of the LATF are discussed in Chapter 3 and
presented fully in Appendix A.
1.2 Background
EPA/OIRM has several major efforts underway to develop policies for sound
management of information resources across the Agency. Wide-scale
implementation of these policies will assure more uniform, consistent, and
compatible information throughout all environmental programs. Agency-wide
data standards adopted thus far include the use of Chemical Abstract Service (CAS)
numbers to identify chemical substances and the assignment of EPA Facility
Identification Codes to regulated facilities. Other Agency-wide data standards define
the Minimum Set of Data Elements for Collecting Ground Water Data and the
specific format for Electronic Transmission of Laboratory Measurement Data. As
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another part of EPA's information management effort, the Agency instituted its
Locational Data Policy. A discussion of the rationale and need leading to
development of the LDP is provided below.
1.2.1 Motivation for Policy Development
The fundamental motivation in developing the LDP has been the growing
need for integrated data to support activities associated with fulfilling EPA's
mission to protect human health and the environment. In order for the
Agency to satisfy demand for solid environmental assessment, risk-based
decision making, and well-founded enforcement actions, EPA must be able to
perform cross-programmatic, multi-media data analyses. To perform these
functions, a common denominator among program data collections must be
developed and used as the basis for data integration. Uniform locational
information of documented quality meets this need.
A tremendous opportunity to successfully conduct cross-programmatic,
multi-media analyses has been created by the increasing availability and cost
effectiveness of sophisticated technologies. For example, Global Positioning
Systems (GPS) now are available to collect extremely accurate locational data.
Geographic Information Systems (GIS) are distributed throughout the Agency
as a tool to perform integrated, location-based analyses.
Finally, data sharing is encouraged by EPA's State/EPA Data Management
(SEDM) Program which links state environmental regulatory agencies and
EPA in partnership. This program seeks to foster data sharing and to
improve data quality and timeliness. The need for a common denominator
exists for sharing data among EPA programs (i.e., Agency-wide) and between
EPA and its state partners.
1.2.2 Concurrent Federal Agency Data Requirements
Another motivation for developing the LDP is the move to standardize
collection and documentation of locational data throughout the Federal
government. Several organizations are responsible for coordinating the
digital cartographic and GIS activities of Federal agencies. For example, in
two Director's Memoranda, dated 4 April 1983 and 18 March 1986, the Office of
Management and Budget (OMB) charged the Federal Geographic Data
Committee (FGDC) with recommending procedures and programs to:
Facilitate the coordination of digital cartographic and geographic
information system activities of Federal agencies
Establish and promulgate standards and specifications for the
production of digital cartographic data.
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As a component of this mandate, the FGDC has created specifications for
locational data, including the use of latitude/longitude as the preferred
coordinate system.
Additionally, committees such as the Federal Geodetic Control Commission
(FGCC) provide recommendations in other relevant areas, including the
most appropriate geodetic datum to be used with locational data and
approved conversion software.
OMB Circular A-16, dated 19 October 1990, established coordination
mechanisms to promote development of a national digital spatial
information resource. It identified specific responsibilities for various
government agencies using locational data, such as the Department of State
and the Department of Commerce. EPA's Locational Data Policy
demonstrates its participation in the movement toward consistently-
formatted, fully-documented spatial data across Federal agencies.
1.3 Contents of this Guidance Document
This document presents guidelines for implementing EPA's Locational Data Policy
and contains the following chapters:
Chapter 2 presents a detailed explanation of the policy requirements,
including the types of entities, data collections, and activities to which
this policy applies, and definitions of the required information.
Chapter 3 outlines the recommendations of the Locational Accuracy
Task Force, including the establishment of a 25 meter level accuracy
goal for location identification data, endorsing use of GPS, establishing
a waiver process, using incentives, and upgrading FINDS.
Chapter 4 explains responsibilities of all participants for implementing
the Locational Data Policy, including the resource commitments that
must be made and the communication links that must be established.
Chapter 5 lists priorities and schedules for implementing the policy
Agency-wide, including historical data conversion, new data collection,
and form/contract tool modification.
Chapter 6 describes the creation of LDP implementation plans required
of all participating environmental programs and initiatives, including
discussion of a sample Table of Contents and required plan
components.
Chapter 7 provides information on available locational data collection
and conversion methods, including guidance on selecting strategies
appropriate for individual programs.
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Chapter 8 discusses the system implications of the Vocational Data
Policy including data field formats and system functional
recommendations.
Appendix A contains full text references of the Locational Data Policy
and final recommendations of the LATF.
Appendix B contains a list of contacts for management, technical, and
other assistance in LDP implementation.
Appendix C presents a partial list of EPA forms that may need to be
modified to comply with the LDP.
Appendix D contains guidance on defining a facility under EPA's
Facility Identification Data Standard.
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Chapter 2
REQUIREMENTS
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2. POLICY REQUIREMENTS
Effective implementation of the Locational Data Policy depends, to a large degree, on
a clear understanding of its requirements and specifications on the part of all
participants. This Policy has several different types of requirements:
Requirements for the types of data, entities, and activities to which this
Policy applies, and
Requirements for the values and formats that must be provided under
this policy.
Each of these requirements is addressed in detail in the sections below. The goals for
the level of 25 meter accuracy and wide-scale use of GPS are presented in Chapter 3.
2.1 Applicability and Scope
This section defines the types of data to which this policy applies, the entities for
which locational data must be collected and documented, and the activities during
which locational data collection should occur.
2.1.1 Data Types Affected by the LDP
The Locational Data Policy applies to all locationally-based information
collected for environmental program support. As a guideline, whenever data
are collected about a place, then corresponding lat/long coordinates and
supporting metadata (method, accuracy, and description) also should be
collected and documented.
Data Collections
The LDP applies to all EPA data collections that are locationally based
(i.e., data about a place), both manual and automated. The LDP applies
to the following types of data bases:
Inventory data bases Data bases that contain inventories
of regulated, tracked, or monitored entities. Examples
include FRDS H, FURS, TRIS, FINDS, AIRS/AFS, IFD, etc.
Compliance tracking data bases Data bases that contain
data on compliance tracking for regulated entities.
Examples include PCS, RCRIS, etc.
Activity tracking data bases Data bases that track
activities such as cleanup, inspections, or enforcement
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actions at a place. Examples include CERCLIS, DOCKET,
etc.
Monitoring data bases Data bases containing ambient
environmental quality data. Examples include STORET,
AIRS/AQ, SCADS, ODES, etc.
Non-locationally based data collections, such as chemical reference
systems (e.g., IRIS) or administrative systems (e.g., IFMS), are not
affected by the Locational Data Policy.
Existing and/or New Data
The requirement for collecting and documenting latllong, method,
accuracy, and description applies to all existing as well as new
locational data.1 General types of existing data collections which may
have to be modified are listed below (programs may assign their own
priorities and approaches to improving the quality of their existing
data):
Data collections with geographic coordinates other than
latllong (e.g., UTM coordinates) Data element fields for
lat/long, method, accuracy, and description should be
created. Values can be supplied by conversion software.
Other locational data (e.g., street address, elevation, etc.)
are not superseded or precluded by information collected
under the LPD.2
Data collections with lat/long coordinates defining the
locations of their entities, but without the lat/long
qualifiers (method, description, accuracy) Data element
fields for method, accuracy, and description should be
created. Although "unknown" values may be
documented as such, data managers should appreciate the
restrictiveness of "unknown" data values and attempt to
supply explicitly-defined values whenever possible.
Data collections with no geographic coordinates Data
element fields for lat/long, method, accuracy, and
description should be created. Lat/long coordinates
should be created by converting existing locational data
^"The requirements of this policy apply to existing as well as new data collections." Ch.13, Sec. 2, p. 13-1, IRM Policy
Manual
2"... lat/long coordinates (are) to be collected and documented with environmental and related data ... in addition
to, and not precluding, other critical locational data that may be needed to satisfy individual program or project
needs, such as depth, street address, elevation, or altitude." Ch. 13, Sec. 5a, p. 13-3, IRM Policy Manual
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(e.g., street address) to lat/long. Method, accuracy, and
description fields should be labeled to indicate that the
coordinate data were derived from conversion (see
Chapter 7 for a description of conversion options).
OIRM has recommended a priority schedule for bringing these types of
collections into compliance with the LDP. Data collections containing
coordinates other than lat/long are assigned the highest update
priority. The rationale behind this recommendation is that such
collections are already coordinate-based and can most easily be made to
conform to the LDP. Of second priority are existing data collections
with incomplete or missing coordinate qualifiers. Of third priority, but
to be completed by December 1995. are data collections with no
coordinate data at all. Due to resource constraints, lat/longs for these
third-priority data sets may have a fairly low level of accuracy.
All newly-collected environmental data must conform strictly to the
formats and accuracy goals specified under the Policy. Requirements of
the LDP and the nature of its minimum accuracy goal are discussed
fully in Chapter 3.
2.1.2 Entities under the Scope of the LDP
The Locational Data Policy applies to all sites, facilities, points, or other
entities regulated, monitored, or tracked under federal environmental law?
In short, any entity or place for which data are collected in support of federal
environmental law must have its locational coordinates defined according to
the Locational Data Policy. In addition, the LDP applies to data collected to
describe conditions of sub-units of a larger entity (e.g., a Superfund site).
Examples of entities requiring LDP-compliant data include, but are not
limited to:
facilities permitted, tracked, or monitored under Federal
environmental law.
Sites that are unique because of an environmental concern but
which may not conform to a property boundary or other
designation as a facility.
Underground storage tanks (especially leaking tanks).
Wastewater-discharge points as defined by and regulated under
the National Pollutant Discharge Elimination System.
*"...for facilities, sites and monitoring and observation points regulated or tracked under Federal environmental
programs within the jurisdiction of ...EPA." Ch. 13, Sec. 1, p. 13-1, IRM Policy Manual
3/92 LDPIG 2-3 -
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Public water supplies, either well heads, key wells in a well field,
reservoirs, or other points of water supply.
Water bodies as defined by states under the Clean Water Act.
Underground Injection Control (UIC) sites which, depending on
the focus of the data collection activity, may be either a well field
or a key UIC well in a well field.
Emission sources of regulated air contaminants (whether
stationary or portable) at permitted, registered, or exempt
facilities.
Monitoring sites where samples are collected to assess
compliance.
Sampling locations where samples are collected to determine
environmental conditions.
Locational data requirements may not apply for entities that are transitory
(i.e., those that change location frequently). Examples of such entities include
waste haulers, mobile air emission sources, and portable operators. Program
managers, however, may wish to capture the boundaries of the area within
which the entity moves or the corridors along which the entity transports.
Note that the LDP does apply to permanent records maintained on places that
are of temporary environmental concern (e.g., spill sites).
2.1.3 Data Collection Activities Affected by the LDP
In the context of EPA's Locational Data Policy, "data collection activities" are
the activities that require definition, collection, and documentation of
locational coordinates. Again, the Locational Data Policy applies to activities
about a place. Therefore, lat/long and supporting qualifiers should be
collected and documented as an integral part of the following activities:
Permit issuance Preparing and issuing permits to operate at a
particular location within regulatory limits. Examples include
permits for wastewater discharge, criteria pollutant emission,
treatment/storage/disposal of hazardous wastes, etc.
Compliance monitoring Monitoring sites to ensure
compliance with Federal standards or permit limits. Examples
include emissions monitoring points, wastewater discharge
points, RCRA monitoring wells, applicable water supply
facilities, etc.
3/92 LDPIG 2-4
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Enforcement Collecting environmental samples as part of case
preparation.
Reporting/notification tracking Tracking compliance with
reporting requirements. Examples include EPCRA responders,
incident reporting (e.g., spills), underground storage tank
notifications, etc.
Cleanup, environmental response -- Collecting data to
determine the magnitude and extent of contamination at a site.
An example would include an NPL site under Superfund.
Environmental monitoring Routine environmental sampling
to determine general environmental conditions for an area.
Examples include ambient air or water quality monitoring,
special studies (e.g., species diversity analyses), etc.
This policy does not apply to activities that are not necessarily locationally-
based. For example, certain grants are awarded based on activity, not location
(e.g., for methods evaluation), and certain enforcement actions are
corporation-based, not location-based. Locational data are not required for
these activities.
In addition, unless the activity generates information on previously
undocumented "places" of concern, or is used as an opportunity to collect
missing or more accurate locational information, it may not be an activity
requiring collection of LDP data. Activities may be conducted at places that
already have adequate locational data. For example, an inspection may occur
at a facility for which locational data were collected and fully documented
during permit issuance. Therefore, the inspection team does not have to re-
collect locational data each time it visits the facility.4
4See description of "incremental" locational data collection in Chapter 7.
3/92 LDPIG 2-5
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2.2 Required Locational Data
This section defines specific requirements for locational data documentation, as well
as specifications for data elements required by the LDP: latitude, longitude, method,
accuracy, and description.
2.2.1 Latitude
Latitude can be defined as the distance north or
south of the Equator as measured in terms of the
360 degrees of a circle. Each line of latitude is an
imaginary circle around the earth, parallel to the
Equator, therefore the lines are referred to as
"parallels of latitude" The Equator is located at 0
degrees latitude and is the starting point for
measuring latitude. The North Pole is located at
90 degrees north latitude and is simply a point, as
is the South Pole, at 90 degrees south latitude.
Therefore, every other point falls somewhere
between 0 and 90 degrees either to the north or
south.
One degree of latitude is approximately 111 kilometers or about 69 miles. A
degree of latitude can be divided into 60 minutes, and a minute can be
divided into 60 seconds.
According to the Locational Data Policy, latitude will be reported in the
following format:
where:
+/-DDMMSS.SSSS5
DD represents degrees of latitude', a two-digit decimal number
ranging from 00 to 90.
MM represents minutes of latitude; a two-digit decimal number
ranging from 00 through 59.
SS.SSSS represents seconds of latitude, with a format allowing
up to ten-thousandths of a second of specificity.
+ indicates latitude north of the equator.
- indicates latitude south of the equator.
5Ch. 13, Sec. 5c(l), p. 13-3, IRM Policy Manual.
3/92 LDPIG
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At a minimum, values for latitude should always be complete to the second
and in accordance with the 25 meter accuracy goal. Data systems, however,
should be capable of handling latitude data to the full length of the format
(i.e., +/-DDMMSS.SSSS) to accommodate more precise measurements likely
in the future.
2.2.2 Longitude
Longitude measures distance east and west in terms of the 360 degrees of a
circle. The lines of longitude meet at the poles and are referred to as
meridians. The prime meridian, internationally accepted as the line of 0
degree longitude, runs through Greenwich, England. All other longitude
measurements are reported as east or west of the prime meridian. Half of the
world is measured in degrees east of the prime meridian, up to 180 degrees,
and half is measured to the west, up to 180 degrees. The 180th meridian is
designated as the International Date Line.
Unlike latitude, where the distance between units is always the same, the
length of a degree of longitude differs greatly with latitude, or distance from
the equator. The closer to the poles, the shorter the length of each degree of
longitude, until it reaches zero at the poles. A degree of longitude, like
latitude, is divided into 60 minutes, and each minute is divided into 60
seconds.
According to the Locational Data Policy, longitude is to be reported in the
following format:
+/-DDDMMSS.SSSS6
where:
DDD represents degrees of longitude; a three-digit decimal
number ranging from 000 to 180.
MM represents minutes of longitude; a two-digit decimal
number ranging from 00 through 59.
SS.SSSS represents seconds of longitude, with a format allowing
up to ten-thousandths of a second of specificity.
+ indicates longitude east of the prime meridian.
- indicates longitude west of the prime meridian.
6Ch. 13, Sec. 5c(l), p. 13-3, IRM Policy Manual.
3/92 LDPIG 2-7
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At a minimum, longitude values should always be complete to at least the
second, in accordance with the 25 meter accuracy goal. Data systems,
however, should be capable of handling longitude data to the full length of
the format (i.e., +/-DDDMMSS.SSSS) to accommodate the more precise
measurements likely in the future.
2.2.3 Method
The Locational Data Policy requires documentation of the method used to
determine lat/long coordinates.7 Locational data accuracy will be technology-
driven to attempt to integrate the most sophisticated technological capabilities
into EPA's data collection efforts. Until June 1992, data collectors may select
any method that is most suitable for meeting Data Quality Objectives (DQOs)
set for the effort. By June 1992, however, the Agency will move toward
widespread use of Global Positioning Systems (GPS) for collecting new
lat/longs when deployment of the full constellation of satellites necessary to
use GPS is completed. A primer on the use of GPS is part of this
implementation guidance package.
The data element method describes the procedure used to determine the
latitude and longitude coordinates. In order for "method" to be most
meaningful to secondary users, it must be documented so that there is
sufficient information to independently reproduce the same locational
coordinates. Therefore, this data element should include fields for
technology (i.e., address matching, map interpolation, Loran-C, or Global
Positioning System, etc.), reference datum (i.e., NAD27 or NAD 83) and map
scale.
It is likely that method will be an essential qualifier used to search lists and
create subsets of coordinates in automated data bases. For this reason, it is
essential to ensure consistency in this data field and establish a definitive list
of the valid values for the field.
Standard documentation of "method" is done best by representing the
method as a code and having qualifying data elements for datum and map
scale. "Method" codes are presented in Exhibit 2-1.
The data element for datum should be in the format BB where BB is the year
of the datum (e.g. 83). The data element for scale should be the "X" value of
the 1:X ratio (e.g., if the scale is 1:24,000, the value of the scale data element
should be "24,000").
^"Specific method used to determine the lat/long coordinates (e.g., remote sensing techniques, map interpolation,
cadastral survey)" Ch. 13, Sec 5c2, p. 13-4, IRM Policy Manual.
3/92 LDPIG 2-8
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Exhibit 2-1
1
Codes* to Document Method
Method
Address matching ADDMAT
Aerial photography w/ ground control
PHOTOGM
Cadastral survey -- SUR-C
Conversion from state plane coordinate
system -- SPCSCONV
Conversion from township-section-range
(etc.) system -- TSRCONV
Conversion from Universal Transverse
Mercator (UTM) coordinates
UTMCONV
Digital or manual raw photo extraction
PHOTORAW
Geodetic quality Global Positioning System
(GPS) Survey -- SUR-GPS
LORAN-C navigation device -- LORAN-C
Map interpolation, via digital source
extractor or manual MAP
Method unknown --UNKNOWN
Navigation- quality GPS -- NAV-GPS
Remote sensing -- RMTSEN
ZIP code centroid -- ZIP
Datum
83 -NAD 83
27 « NAD 27
00 ~ Datum unknown
Spatial Reference
(scale of source map or photo)
Scale
7.5' X 7.5' (1:20,000)
7.5' XI 5' (1:20,000)
7.5' X 7.5' (1:24,000)
7.5' X 15' (1:24,000)
7.5' X 7.5' (1:25 ,000)
7.5' XI 5' (1:25,000)
1 5' X 15' (1:62,500)
7.5' X 20' (1:63,360)
7.5' X 36' (1:63,350)
1:15,840
1:20,000
1:24,000
Not Applicable
Unknown
Data Element Value
20,000
20,000
24,000
24,000
25,000
25,000
62,500
63^60
63,350
15340
20,000
24,000
NOT APPLICABLE
UNKNOWN
S3
Codes are maintained by EPA's CIS Program within OIRM; codes may be made available within the standards category on GISNET
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2.2.4 Accuracy
The Locational Data Policy requires documentation of the accuracy of the
coordinates. The accuracy data element is intended to enable users to
determine whether a lat/long measurement is adequate for their applications.
"Accuracy" is a quantitative measurement of the amount of deviation from
true value present in a measurement, (i.e., accuracy describes the correctness
of a measurement). This term is different from precision which is a
quantification of the range of variation normally present in a measurement
technique (i.e., precision describes the likelihood of the same values being
repeated in another measurement).
For example, ten people who read the coordinates of a particular point on a
map could be fairly accurate as all ten could obtain coordinates which are very
close to the actual coordinates of the point. Because each individual is
applying different subjective judgments when reading the map, there could
be considerable variation between individual readings resulting in poor
precision for the technique. Conversely, a poorly calibrated LORAN receiver
used by the same ten people at the same location would likely yield
coordinates which were nearly identical, resulting in high precision. The
coordinates obtained, however, would not be accurate because they would not
be close to the actual location.8 The difference between precision and accuracy
is illustrated in Exhibit 2-2.
The issue of requiring that a particular level of lat/long accuracy has been
addressed by the Locational Accuracy Task Force. The Task Force has
recommended an accuracy goal of 25 meters. This visionary goal is discussed
in detail in the next chapter.
It has been noted that distance represented by a degree of latitude remains
constant throughout the world whereas the distance represented by a degree
of longitude varies from the poles to the equator. For example, the number
of meters on the ground represented by a 1.0 second accuracy for longitude at
the equator (0 degrees latitude) would be larger than + 1 second accuracy at the
poles (90 degrees latitude). Additionally, + 1.0 second of accuracy for latitude
and for longitude is similar only at the equator. Therefore, to be fully
descriptive, coordinate pairs would require two accuracy measurements; one
for latitude and one for longitude. Due to the additional burden on data
storage, however, the LDP requires that only the lowest accuracy
measurement be recorded, regardless of whether it is for longitude or for
latitude. With such an arrangement, the user community will know that
both coordinates are at least as accurate as the reported value.
""No Minimum Required Accuracy! The Voice of Reason," Task Force on Locational Accuracy, White Paper #2,
pp. 3-4.
3/92 LDPIG 2-10
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Exhibit 2-2
Precision vs Accuracy
Accurate, but not
precise
Precise, but not
accurate
Accurate and
precise
Neither accurate
nor precise
3/92 LDPIG
2-11
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Accuracy is to be presented as a range within which there is 95% confidence
that the true lat/long value falls. The format for presentation of accuracy is:
+/- X units
where units are degrees, minutes, seconds, or decimal fractions of a second.
Accuracy should be presented to one decimal place smaller than the units in
which the lat/long coordinates are reported. Therefore, if coordinates are
presented in whole-tenths-of-seconds, it is because they have been "rounded
up" from some value in hundredths-of-seconds, and the accuracy is described
as the range, in hundredths of seconds, within which the true value has a
95% chance of falling. To illustrate, lat/long coordinates reported as:
+432430.3,-1295720.8
which are presented to the whole tenths-of-seconds may have an accuracy of:
+/- .05 sec
In general, to meet the 25 meter goal, accuracy should be determined to
within fractions of a second. The data collector must identify that value of
the units (in this case, 5 hundredths of seconds) within which there is 95%
confidence that the true location falls. More information on the 25 meter
goal recommended by the Locational Accuracy Task Force is presented in the
next chapter.
2.2.5 Description
Lat/long coordinates are often collected to be representative of an entity but
are actually of a particular point or portion within the entity. Thus, the
"lat/long of a facility" might actually be the lat/long of the entry-point of the
property; or of the lat/long of an effluent sampling point at that facility.
Because secondary users need to know exactly what the lat/long coordinates
define, the Locational Data Policy requires a description of the exact place
where the coordinates were collected.
Because the exact locations to which coordinates refer can vary a great deal
and are difficult to generalize, the format of the description data element is a
free-format, text field. There should be, however, two components
documented for "description:"
The exact entity that the latflong(s) are o£ (NOT what they
represent, such as being Q£ the driveway but representing the
whole facility)
Whether the coordinates describe a point, line, or area.
3/92 LDPIG 2-12
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Data collectors should be consistent in their use of the description field. The
exact place used to represent the location of the entity should be selected
when planning the data collection process.
2.3 Recommended Locational Data
Although it is not mandatory under this policy, it is strongly recommended that all
data bases containing locational coordinates also contain date of collection and
source. Date of collection is important because it enables secondary users to draw
inferences about locational data. For example, if the original locational data were
collected prior to the current revision of the base map, then the locational data may
be incompatible with other points on the map.
To provide another basis for evaluating the data for re-use, the source of the
locational data should also be documented. Source refers to the organization that
actually collected the coordinates, (e.g., EPA office, a state environmental
organization, a regulated entity reporter, or a specific contractor). This type of data
gives secondary users more information by which to evaluate the quality of data
because of what might be known about the collector's technique. It also enables the
secondary user to contact the original collector with specific questions regarding
compatibility.
Because they are not formal parts of the current policy, these elements are
considered optional. If collected, they should be stored in additional fields. No
specific formats for these fields have been established.
2.4 Special Considerations
Some important guidelines and principles for the collection and documentation of
locational data are presented in this section.
2.4.1 "Tiering" and Spatial Extent
A common concern of data collectors is how to comply with the Locational
Data Policy in terms of identifying an entity in the appropriate spatial terms.9
This concern can be exemplified by three questions:
My "facility" is a complex entity; what portion of it (e.g., the back
door, the driveway, the discharge pipe, the center of the
building) is appropriate to document with latflongs?
My site is extensive; should the coordinates represent a point,
line, or area?
"...The coordinates may be present singly or multiple times, to define a point, line, or area, according to the most
appropriate data type for the entity being represented..." (Ch. 13, Sec. 5c(l), p. 13-3, IRM Policy Manual)
3/92 LDPIG 2-13
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When is an area represented by a point? When by a polygon?
The LATF has termed the first concern as "tiering" in recognition of the fact
that an entity of environmental concern can have several "levels" of interest.
For example, a site may have several facilities on it, each one with several
sources of air emissions, each with several points of emission. Each level of
interest on this site can be classified according to a different "tier." The tier to
which the other attribute data belong (e.g., as monitoring or site description
data) is the tier for which location identification data must be collected and
documented. The rationale behind this guideline is that every data
collection project will have a specific objective in mind, and locational data
will probably never be collected alone (except in some cases of centralized
locational data collection, as defined in Chapter 7). Therefore, monitoring
data that describe the composition of effluent from a particular discharge pipe
should be accompanied by locational data identifying the geographic position
of the pipe, not necessarily of the whole facility. Locational data to accompany
general facility emissions and discharge data, such as required under EPCRA
where the activities are described for the whole facility, should be of the
facility in general, and not of each point within the facility.
It is likely that several sets of coordinates will be collected for a single site
because many facilities are composed of sub-units, each having a distinct
environmental concern. Locational data from the different tiers of that
facility will be distinguishable from each other by the required DESCRIPTION
field, which must tell precisely to what the lat/longs refer (discussed below).
When the "facility in general" is the proper spatial scope, the data collector
must determine which point (e.g., the entry point, northeast corner, etc.) will
be used to represent the facility. This determination is made by taking into
account how the data being collected are to be used. The data collector must
determine the single point that is most representative of the entire facility
and document it in the "DESCRIPTION" field. The Guide to Selection of
Latitude/Longitude Collection Methods accompanying this LDPG provides
information on using a single point to represent a whole facility. Appendix D
of this document presents the definition of a facility as given in the 12/13/91
version of the FIDSIP.10 In general, if a single point is used to represent an
entire facility, it should be the most visible and accessible point (to ensure
precision or "repeatability") and should be identified in the description field.
A similar principle guides determining the most appropriate spatial
representation (i.e., point, line, or area) for an entity. In general, this
determination is based upon how the data are to be used. For example, if the
application of the data collection is national in scale, then a detailed spatial
description (e.g., many points defining a polygon outlining the exact
10The Facility Identification Data Standard Implementation Plan (EPA/OIRM, 12/91)
3/92 LDPIG 2-14
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boundaries of a site) need not be collected and documented; one set of
coordinates to describe the entity location will suffice. If the data are collected
to support a focused study (e.g., requiring delineation of exact boundaries of
contamination), then the location definition should be reflective of the
entity's geographic "shape" (i.e., an "area" or "polygon").
Another basis for determining whether an area should be represented by a
point or a detailed polygon is the scale of the map used in the primary
application of the data. If a polygon plotted on a map of the appropriate scale
for the data's primary use is indistinguishable from a representative point for
the same area at the national map accuracy standard11 (i.e., the polygon will
be so small that it appears as a point measured on the map at the scale being
used) then only one set of coordinates must be defined to represent the site.
When one set of coordinates represents the location of an entity, that one set
of coordinates is supported by one set of values for method, accuracy, and
description. If many sets of coordinates are collected to represent a single
entity, the same is true: all of those sets of coordinates are supported by a
single value for method, accuracy, and description (i.e., lat/long coordinates,
whether collected singly or as a set defining a polygon, are qualified by a single
set of method-description-accuracy). This concept is illustrated in Exhibit 2-3.
2.4.2 Standard Datum
To make them most meaningful, locational identification data should be
linked to a standard datum. A standard datum is a network of monuments
and reference points defining a mathematical surface from which geographic
computations can be made. Documentation of the datum used to determine
lat/long coordinates helps compensate for the fact that the actual shape of the
earth is not a perfect sphere but instead is an oblate spheroid (flattened at the
poles and bulging at the Equator). When the Earth is cut along its polar axis
the cross-section approximates an ellipsoid.12
In the past, the North American Datum of 1927 (NAD27), based upon the
Clarke 1866 ellipsoid, has been used as the locational basis within the Agency.
Recently, however, the National Geodetic Survey has redefined and
readjusted NAD27, resulting in the North American Datum of 1983 (NAD83).
This system is an Earth-centered datum using the Geodetic Reference System
1980 ellipsoid as its basis. The datum shift from NAD27 to NAD83 has
resulted in a change of latitude and longitude for all points on a map and a
change in the positions of the grid coordinates. Specifically, the 1990 Federal
Digital Cartography Newsletter estimated that this change caused coordinate
shifts in the eastern United States ranging from 3 to 40 meters and in
true location is within a horizontal distance of 0.02 inches on the map being used.
12"Implementing the North American Datum 1983 for the National Mapping Program/ United States
Department of the Interior.
3/92 LDPIG 2-15
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Exhibit 2-3
Relationship of Method, Accuracy, and Description
To Lat/Long Coordinates
When Lat/Long is a Single Set of Coordinates
Defining a Point or Representing an Area
or -
Area
When Lat/Long is given as Multiple Sets of Coordinates
Defining a Polygon Outlining an Area
1
Lat/Long 1A
Lat/Long 2A
Lat/Long 3A
Lat/Long 4A
Lat/Long 5A
Lat/Long 6A
* Assumes all 6 coordinate pairs were collected using the same method and have the same accuracy
3/92 LDPIG
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California and other parts of the western United States of more than 100
meters.
The National Geodetic Survey Division is encouraging all Federal agencies
who use or produce spatial coordinate information to make the transition
from NAD27 to NAD83. Even though the majority of EPA's data and most
base maps for the United States are in NAD27, EPA data collectors should
begin using NAD83 at this time if they are not already doing so.
Conversion of old data should begin as soon as possible. EPA data collectors
will be able to use datum conversion software known as NAD CON (North
American Datum Conversion), developed by the National Geodetic Survey.
This program, written in FORTRAN 77, allows conversion of large amounts
of coordinate data in ASCII format from NAD27 to NAD83. Conversion
accuracy of approximately 0.15 meters is achievable within the conterminous
United States and slightly lower accuracy levels (not more than 1.0 meter) in
more remote areas of the country. EPA has developed software for
conversion of locational data that is in ARC/INFO format from NAD27 to
NAD83. This conversion software, known as CDATUM, is available from
EMSL-Las Vegas (refer to Appendix B for a contact in EPA/ORD). Data
conversion options are discussed in greater detail in Chapter 7.
Due to the transition to NAD83, it will be critical for data collectors to have
documented the datum utilized in the collection process so that conversion
to NAD83 can be made to only those coordinates needing it. Therefore, for
each location definition (either a single set of coordinates or several sets
representing a line or an area), the datum used as the basis will be recorded as
part of the METHOD field. Complete guidelines on documentation of
method are given in Sec. 2.2.3 of this chapter.
3/92 LDPIG 2-17
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{W4M4gM-Mm^X^X^-A->MvvM^^
Chapter 3
RECOMMENDATIONS OF THE LATF
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3. RECOMMENDATIONS OF THE LATF
Chapter 1 of this document introduced the Locational Accuracy Task Force (LATF), a
group of senior management and technical professionals from EPA and state
environmental agencies convened to develop recommendations on locational data
accuracy for EPA's IRM Steering Committee. Over a period of six months, the LATF
collected and weighed a considerable amount of information on geocoding
technologies and programmatic requirements. Their efforts resulted in a series of
recommendations which have been incorporated into the Locational Data Policy.
All EPA personnel and personnel of its agents or state program delegates must
address the LATF recommendations in order to comply with the LDP. Details of the
LATF recommendations are summarized in the sections that follow and are
presented in full in Appendix A.
3.1 Introduction
The consensus of the LATF was that accurate, well documented locational data are
essential to risk management and multi-media decision making. They recognized
that, even though some EPA programs, regions, states, and other Federal agencies
have taken significant steps to develop locational policies, unless a clear goal is
stated, the Agency's data collections will remain a "mixed bag." The group
recommended a technology-based goal, centered around Global Positioning Systems
(GPS) and photo interpretation/map interpolation to yield a goal of 25 meter
accuracy for all coordinate points.
It is important to note that all EPA programs except RCRA and CERCLA already
have regulatory requirements for collecting latitude and longitude as descriptors of
location (OSWER has non-regulatory program directives for RCRA and CERCLA).
These programs have a variety of accuracy specifications, ranging from 1 to 15
seconds (approximately 25 to 375 meters). With full implementation of the
Locational Data Policy, EPA is striving to have all its lat/long information
documented and at least as accurate as 25 meters.
3.2 Summary of the LATF Recommendations
The LATF recommended five general goals for implementing a locational standard
as follows:
Establish an Agency-wide goal of better than 25 meter accuracy for
locational data by 1995.
Encourage the use of the most practicable and accurate technology for
determining lat/long coordinates, currently recommended to be GPS
technology (with interim use of map interpolation between now and
1995).
3/92 LDPIG 3-1
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Institute of a process for administering waivers from LDP requirements
for certain data collection efforts.
Develop an incentive program to move the entire environmental
community, including states and industry, toward the 25-meter
locational accuracy goal.
Enhance FINDS to be a source of general locational data for regulated
facilities.
All of these recommendations were made to initiate a program whereby the quality
of EPA's locational coordinate data continually improves. New data are of highest
priority for compliance under the 25-meter accuracy goal. Beginning immediately,
any collection effort during which new locational data are gathered (e.g., during site
visits, permit renewals, or special studies) should yield data accurate to at least 25
meters. By 1995, all latllong measurements in Agency data collections should have
accuracies of better than 25 meters. Therefore, by 1995 all locational data will be
collected in a consistent method, will be of documented quality, and will thus be
more valuable in any application.
3.3 Specifics of the LATF Recommendations
The five components of the LATF recommendations are discussed in more detail
below and are presented in full in Appendix A.
3.3.1 Accuracy Goal
The Agency-wide goal for all lat/long data is accuracy of better than 25 meters.
A plan for reaching this goal will be initiated immediately to phase in the
necessary procedural and system changes.
The goal was established at 25 meters because:
Review of program requirements shows that EPA data will be
more amenable to secondary use if the quality of its location
identification data is improved to 25 meter accuracy.
Examination of locational data accuracy requirements currently
in EPA programs and in other agencies shows a target of 25
meters to be consistent.
Accuracy to the 25 meter level is becoming more achievable with
improvements in technology.
The accuracy limit was established as a goal and not a standard for several
reasons. First, achievement of maximum locational data accuracy is
necessarily technology-based (i.e., the quality of locational data should be as
3/92 LDPIG 3-2
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good as the most practicable data collection technology). This technology
constraint currently may limit the accuracy of locational data to 25-100 meters
but will improve with time to be better than 25 meters (see the discussion of
GPS technology below). Second, the complexity of the processes that must be
put in place to achieve this level of accuracy makes the concept difficult to
enforce, and participation-encouraging incentives were deemed more
effective than enforcement mechanisms.
The target date for full implementation of the locational data accuracy goal is
December 31, 1995. By this date, global positioning system technology will be
mature, and enough time will have passed for updating to EPA data systems
to accommodate the new, accurate locational data.
3.3.2 Technology-Based Locational Data Accuracy
The technology to produce highly accurate locational coordinates is
improving rapidly. Techniques for map digitization, address matching, and
global positioning are becoming more feasible every day. Therefore, the
LATF recommendation is to have the best available technology applied to
collection of locational data.
GPS technology has been determined to be an effective way of producing
accurate locational data. When the constellation of satellites upon which this
technology depends is fully deployed in 1992, means for collecting accurate
locational data will be fully available to EPA and its partners. At that time,
accuracies of 10 meters or better will be achievable with a high degree of
confidence and precision. The use of GPS in all data collection efforts after
June 1992 will ensure that:
The most accurate locational data are obtained.
Equipment purchases and subsequent training requirements are
minimized.
The type of information being reported is uniform.
Several issues that must be resolved prior to full utilization of GPS
technology have been identified as:
The requirements for the amount and type of global positioning
devices needed.
The absence of documented procedures for using GPS
technology and the mechanisms for transmission of locational
data from the field to the data bases.
3/92 LDPIG 3-3
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The amount of training and software necessary to properly apply
GPS technology.
The difference in approaches needed for arriving at a conclusion
about locational data obtained in the field as opposed to in the
office.
The need to standardize a representative part of a facility for
which locational data will be collected.
In addition, GPS technology may not prove to be the most suitable data
collection technique in all cases. Selective availability of satellite signals may
degrade the quality of results, weather or topographic conditions might
influence the readings, and the availability of trained personnel or equipment
might compromise accuracy. Therefore, although GPS is the preferred
technology for acquiring location identification data, it is not the only
acceptable method.
3.3.3 Waiver Applications
In some instances, it may not be appropriate for a data collection effort to
meet the requirements of the LDP. Impediments to meeting policy
requirements and regulatory restrictions, such as the type of location
identification data required, its accuracy, the method used, or the schedule for
implementation may be difficult to overcome. A process must therefore be
developed for obtaining waivers to the LDP. This process must ensure
uniform consideration of waiver requests without compromising the
objectives of the LDP.
Program managers must prepare waiver applications to be presented to the
IRM Steering Committee. The waiver applications need be nothing more
than clearly defined Data Quality Objectives (DQO) reports. For each data
collection effort, the waiver applications should present the following:
The contrast in objectives between the data collection effort and
the Agency-wide locational data accuracy goal.
The approach that will be used to meet the locational accuracy
needs of the data collection effort.
Justification for not meeting LDP requirements.
3.3.4 Incentives
Strict enforcement of a level of locational data accuracy is infeasible because of
the wide range of participants (states, industry, etc.) and the different accuracy
levels that can be achieved by each type of technology. Motivational
3/92 LDPIG 3-4
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incentives are much more effective than enforcement. The need to share
data and the benefits of reduced data collection costs should be a sufficiently
powerful incentive. Appendix A details some incentives that were identified
by the LATF.
3.3.5 Enhancements to FINDS
EPA/OIRM's Facility INDex System (FINDS) is ideally positioned to be a
gateway to all facility data. FINDS is currently undergoing an enhancement
effort to accommodate changes that have occurred since its original design,
such as the adoption of a Facility Identification Data Standard prompting the
connection of many new data bases to FINDS.
FINDS contains basic identification information on every facility regulated by
EPA (state use of FINDS is beginning on a pilot basis). In addition, each
facility record in FINDS contains references to sources of more detailed
program data. The current version of FINDS can house one set of locational
coordinates per facility record.
Enhancements can be made to FINDS to make it a more comprehensive
source of facility locational data. Such enhancements will reduce the need for
collection of new locational data and serve as a way to double-check the
quality of program locational data. The recommended enhancements to
FINDS are:
Employment of address matching and other techniques to
populate/improve the lat/long coordinate data elements in
FINDS.
Inclusion of accurate lat/long coordinates for sub-facility tiers
such as discharge pipes or stacks.
Edit capabilities to detect changes in locational data within
program systems.
"Gateway" capabilities to directly link program source data bases.
Structured Query Language (SQL) capabilities to enhance access
to FINDS locational data.
A requirements analysis and DQO report may be necessary to detail the exact
specifications and implications of each of these recommendations. In
addition, an effort to make source data bases compatible with FINDS may
have to be initiated.
3/92 LDPIG 3-5
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Chapter 4
RESPONSIBILITY AND AUTHORITY
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4. RESPONSIBILITY and AUTHORITY
Successful implementation of the Locational Data Policy will require the
cooperation of many affected organizations. In this chapter, the specific authorities
and responsibilities under the LDP of EPA's IRM Steering Committee, OIRM, other
EPA offices and programs, the state delegates of Federal environmental laws, and
other designated representatives will be discussed.
4.1 The IRM Steering Committee
The IRM Steering Committee, made up of individuals drawn from OIRM, EPA
Regional and Program offices, as well as state governments, oversees activities and
resolves issues relevant to environmental information management. For example,
a subcommittee of the IRM Steering Committee, the LATF, developed a set of
recommendations for establishing a goal for locational data accuracy which has been
incorporated into the original LDP.
Waivers may be necessary for certain aspects of the LDP. To institute a waiver
evaluation process, the ERM Steering Committee will:
Design a procedure for waiver processing.
Develop and publish waiver evaluation criteria.
Define roles and responsibilities in the waiver process.
Establish monitoring and enforcement mechanisms for LDP
requirements.
Support will be provided to the IRM Steering Committee by OIRM/IMSD, various
inter-organizational committees, and program managers (see below).
4.2 OIRM Responsibility and Authority
The Locational Data Policy describes OERM's responsibilities in a general sense. The
LDP states that "OIRM shall:
Be responsible for implementing and supporting this Policy.
Provide guidance and technical assistance where feasible and
appropriate in implementing and improving the requirements of this
Policy."
Responsibilities within OIRM for implementing the Locational Data Policy lie
primarily within two OIRM divisions: the Information Management and Services
Division (IMSD) and the Program Systems Division (PSD). Additionally,
implementation guidance to managers of scientifically-oriented data systems can be
3/92 LDPIG 4-1
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provided by OIRM's Scientific System Staff (SSS). There are several programs
within theses groups that will have a key role or involvement with the LDP and
include the Geographic Information Systems Program (GIS) and the SEDM Program.
"Tools" that OIRM will use to help implement the LDP include:
The IRM Policy Manual.
The Catalog of Agency Data Policies and Standards.
Standard EPA forms.
FINDS.
The Gateway.
The GIS network.
The IRM Steering Committee.
Networks of senior IRM officials, Regional IRM Branch Chiefs, system
managers, and SEDM Coordinators.
Grants (e.g., SEDM).
Cooperative agreements and memoranda of understanding.
The LDP Guidance Documents.
The following sections will define each of these OIRM responsibilities by division
within OIRM. The current organizational structure of OIRM is displayed in
Exhibit 4-1. Divisional responsibilities under the LDP are summarized in
Exhibit 4-2.
4.2.1 IMSD
Two branches within IMSD, the Information Management Branch (1MB) and
the Information Sharing Branch (ISB), will have responsibilities in LDP
implementation. 1MB has played a lead role in supporting the LATF and in
developing the LDP and this implementation guidance. 1MB also is
responsible for the Agency forms program, which may be used to enhance
standardization of locational data within EPA. 1MB will continue to play a
role in LDP implementation, including initiating program-specific planning
processes, overseeing LDP progress, and coordinating development of
information management standards, and policies associated with the LDP.
ISB is responsible for assisting and coordinating the implementation of
this policy at the state level under the auspices of the State/EPA Data
3/92 LDPIG 4-2
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OJ
Ss
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S
n
Exhibit 4-1
MPES
Information
Management and
Services Division
OIRM Organizational Chart
(1/92)
Office of
Information
Resources
Management
Program
Systems
Division
sss
Administrative
Systems
Division
Information
Management Branch
Information Access
Branch
Information Sharing
Branch
Systems Planning and
Analysis Branch
Systems Maintenance
and Development Branch
Information Integration
and Management Branch
Client Support Branch
Technology Branch
Technical Support and
Development Staff
Administrative Systems
Support Branch
Administrative Systems
Development Branch
-------
Exhibit 4-2
Oi
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OIRM Responsibilities under the Locational Data Policy
Responsibilities
Produce Agency-wide guidance for LDP
implementation
Coordinate data standards and policies to assure
consistency with LDP
Conduct reviews of LDP implementation progress to
assess effectiveness
Provide assistance in development of Program or
Environmental Initiative LDP Implementation Plans
Aid states in identifying grant funds and available
technical resources and identify data sharing and
technology transfer incentives for non-EPA participants
through State/EPA Data Management Program
(SEDM)
Provide guidance on form and procedure modifications
Provide technical leadership for LDP implementation
through the GIS program
Promote locationally-based data integration through
efforts such as the Gateway
Ensure that EPA spatial and locational data policies are
compatible with Federal government standards and
policies by participation in the FGDC
Provide access or reference to locational data via
FINDS
Ensure STORET compliance with LDP
-------
Management (SEDM) Program. ISB will foster cooperation between states
and EPA during implementation of the LDP. Mechanisms that may be used
to encourage participation include technology transfer and application of
financial assistance grants for data integration. Conforming to international
standards, the Agency's approach to collecting and documenting locational
data will be shared with other countries via ISB's International Data Sharing
Program.
4.2.2 PSD
PSD provides general support and guidance to most EPA system
development efforts. In this capacity, PSD is responsible for ensuring that
LDP requirements are addressed in every system development effort. Most of
PSD's responsibilities in the implementation of the LDP lie within the
Information Integration and Management Branch (UMB). The GIS Program
in IIMB will have a lead technical role in LDP implementation. This
program will be the focal point for spatial information resources, such as
GRIDS, GIS policy, and national GIS activities. IIMB will encourage
locational data sharing and exchange with all of its "clients" and contacts
through its data integration function, including development of the EPA
Gateway. Additionally, IIMB will continue to be responsible for ensuring that
EPA is meeting Federal government standards for spatial data, as established
byFGDC.
PSD's Systems Maintenance and Development Branch (SMDB) is responsible
for upkeep of the FINDS System. SMDB will provide general lat/longs (when
available) for each facility in the "master record" file, and can capture
lat/longs from program systems for facility sub-portions in the FINDS "alias
file." SMDB also will ensure STORET compliance with LDP requirements.
4.2.3 Resources from OIRM
Implementation of this Policy will require a partnership between OIRM, the
programs, and other key participants (e.g. states, the regulated community).
OIRM will work with managers in media programs and environmental
initiatives to determine resource requirements and appropriate sources of
assistance.1 States may work through their SEDM and EPA program liaisons
for possible assistance.
LDP participants are expected to extend their data collection resources to
ensure availability of the locational data necessary to meet the requirements
of the LDP. However, OIRM will provide certain resources that may reduce
the financial burden. These resources include:
IA methodology for determining costs for LDP implementation can be found in the Guide to Selecting
Latitude/Longitude Collection Methods, accompanying this LDPG.
3/92 LDPIG _ 4-5
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Guidance documents.
LDP implementation plan development workshops.
Data conversion assistance (software, technical assistance).
System development guidelines, including available software
for edit checks to assure locational data accuracy, completeness,
and consistency (e.g., comparison of coordinates to county
boundaries).
Possible funding for systems enhancements through the System
Development Center (SDC).
A central repository or access capability to existing locational data
for regulated facilities through the Facility INDex System
(FINDS).
News bulletins on developments which may affect
implementation of the LDP or technology transfer ("GISNET").
A program for data sharing, financial assistance, and technology
transfer with states through the SEDM team including potential
funding through SEDM's financial assistance program.
When substantial improvements to a system are required to implement the
Locational Data Policy, and the requestor can demonstrate not only mission
criticality but broad benefits to other environmental activities (i.e., "secondary
usability" of data enhanced by more comprehensive locational data), this
system will be given priority for resource allocation by OIRM.
4.2.4 Authority
OIRM's authority in implementing the LDP stems from Agency-wide
concurrence with the LDP at the Assistant Administrator level. Additional
authority is derived from the following sources:
15 CFR, Part 6 Subtitle A, Standardization of Data Elements and
Representations Establishes a Federal program for
standardizing data elements and representations that are used
and interchanged in government data systems, expanding the
utility of every data collection and avoiding duplication of effort.
Geological Survey Circular 878-B, A U.S. Geological Survey Data
Standard, Specifications for Representation of Geographic Point
Locations for Information Interchange Recommends formats
for documenting location identification data.
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Federal Inter-Agency Coordinating Committee on Digital
Cartography (FICCDQ/U.S. Office of Management and Budget,
Digital Cartographic Data Standards: An Interim Proposed
Standard Provides recommendations for a systematic and
comprehensive set of digital representations of cartographic
features to support various cartographic data systems and spatial
data transfer.
EPA Regulations 40 CFR 30.503 and 40 CFR 31.45, Quality
Assurance Practices under EPA's General Grant Regulations
Establish requirements for grantees involved with
environmentally-related measurements or data generation to
develop and implement quality assurance practices for
producing adequate data meeting project objectives, and
minimizing loss of data due to uncontrollable conditions or
malfunctions.
"Policy and Program Requirements to Implement the Quality
Assurance Program" (EPA Order 5360.1 ) Requires users to
specify data quality needs and the quality control necessary to
assure that the resulting data satisfy intended uses. This order
also requires thorough, verifiable, and defensible documentation
so that data quality is known.
Locational Accuracy Task Force Findings and Recommendations
(December 13, 1990) ~ Establishes the goal of 25 meter accuracy
for lat/long to be implemented by 1995 and identifies the steps
needed to achieve that goal.
OMB Circular A-16 (revised 10/19/90) ~ Establishes coordination
procedures and assigns responsibilities to government agencies
involved with spatial data analysis.
OIRM intends to monitor the effectiveness of the LDP to ensure that it is
being properly implemented by all data generators and that it is meeting the
goal of improving secondary data usability. Data collection efforts will be
reviewed to assess whether documentation of lat/long data and
corresponding attributes (method, description, and accuracy) are included.
4.3 Other EPA Offices and Programs
Because the LDP promotes consistency across the entire Agency, all offices and
programs that collect locational data will have responsibilities in implementing it.
These off ices/programs and their responsibilities are summarized in Exhibit 4-3.
More complete details are provided in the sections that follow.
3/92 LDPIG 4-7
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Exhibit 4-3
EPA Office and Program Responsibilities under the Locational Data Policy
Non-Media Program Office
Responsibilities
Media Program Office
Responsibilities
Office of Research and Development
Evaluate LDP data collection methods for cost and
accuracy
Conduct technical research for GIS/GPS and spatial data
application and collection (including publication of the
GPS Primer)
Implement DQO Program as it relates to LDP
Implement LDP in EMAP
Office of Policy, Planning and Evaluation
Aid programs in meeting LDP requirements when
collecting data from the public
Interact with OMB on behalf of programs for new
information collection requirements
Regional Offices
Regional IRM organizations will serve as local sources for
information, guidance, and monitoring during LDP
implementation
State/EPA Data Management Coordinators will work with
other regional staff to facilitate implementation
Environmental Services groups will provide technical
assistance and guidance on locational data collection
efforts
NDPD/OARM
Analyze need for Agency-wide vehicle for procuring GPS
equipment
Promote LDP compliance throughout client community
Regional GIS/GPS Work Groups
Promote adherence to LDP principles in activities
involving spatial data
Environmental Initiatives
Ensure LDP is planned and fulfilled.
Develop Program LDP Implementation Plans
Develop or redirect existing data collection and
documentation policies and procedures to meet
the requirements of the LDP
Implement changes to documentation tools, such
as forms, grant documentation, contracts, etc.,
including instructions on locational data
collection
Arrange for adequate resources to implement
LDP within the program
Address LDP requirements in planning processes
Coordinate with OIRM to establish priorities for
policy implementation
Provide support for policy implementation
throughout program with personnel, agents,
grantees, delegates, and the regulated community
Develop DQOs in support of data collection
planning and waiver requests
-------
4.3.1 Non-Media Program Office Responsibilities
Responsibilities for LDP implementation reside with several offices whose
activities affect or involve media programs, but which are not media
programs themselves.
Office of Research and Development
The Office of Research and Development (ORD) has several critical
functions in effective implementation of the Locational Data Policy.
ORD responsibilities include:
Methods evaluation ORD takes the lead in evaluating
all measurement methods in EPA, including those for
locational data. ORD will be responsible for reviewing
existing and new technologies for collecting locational
data and making recommendations on the costs, accuracy,
benefits, and limitations of each method.
CIS development activities - ORD's EMSL facility in Las
Vegas, which is a Center of Excellence, and its EPIC facility
in Warrenton, Virginia, are responsible for conducting
technical research in the effective use of GIS technology
and spatial data application and collection.
GPS technology expertise Because the locational
accuracy goal of 25 meters is technology based, and because
GPS is the recommended locational data collection
method, ORD will be the Agency's contact for the
application of GPS technology. ORD produced the GPS
Primer accompanying this document and ORD will
continue to assess technological developments and
monitor the best methods for achieving the Agency's
locational data accuracy goal.
Data Quality Objectives (DQOs) - ORD is responsible for
assuring that the objectives of the LDP are addressed
during the data-collection planning process, including
DQO development. DQOs will be a key part of the policy
waiver process. ORD offers guidance and technical
assistance to all decision-makers and data collectors in the
process of the DQO development.
Environmental Monitoring and Assessment Program
(EMAP) -- ORD is responsible for developing and
implementing EMAP and will ensure that LDP
requirements are met in this program.
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Office of Policy, Planning and Evaluation (OPPE)
Among other responsibilities, OPPE assures that EPA is in compliance
with certain portions of the Paperwork Reduction Act. Toward that
end, OPPE administers the Agency's information collection budget and
works to facilitate OMB approval of information collection requests
when gathering data from the public. Therefore, OPPE will be
involved with implementing the LDP when data to satisfy LDP
requirements must be collected from the public (i.e., regulated
community).
In particular, OPPE will provide guidance and assistance to all
programs that depend on the regulated community to provide some or
all of their locational data. Activities may involve creation or
modification of forms used for data collection, as well as support in
developing justifications to the Office of Management and Budget
(OMB) for increases in information collection burdens. Where
appropriate, OPPE will interact with OMB on behalf of the programs to
help justify collection of information necessary to comply with the
LDP.
In its policy review capacity, OPPE will be responsible for developing
and/or reviewing rules, regulations, policies, and guidelines to ensure
compliance with the LDP. OPPE will notify and work with OIRM to
promote modifications to these items as necessary to ensure
consistency with the LDP.
Regional Offices
Most environmental programs are conducted through EPA's regional
offices, either directly by regional staff or through delegation to states in
the region. Each regional office has several organizations that will play
a key role in LDP implementation. These organizations include:
Regional IRM organizations- The regional IRM
organization will be responsible for working with regional
program staff to promote LDP compliance during all
appropriate activities, such as inspections, site cleanup
management, enforcement actions, permit issuance, or
compliance monitoring. The regional IRM organizations
will be the local source for guidance and information on
policy requirements and resource access, similar to OIRM
within EPA/HQ. Regional IRM personnel also will
promote awareness of the LDP at a regional level so that
complete and accurate LDP data are entered into
appropriate computer data bases hi a timely manner.
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SEDM Coordinators SEDM coordinators will work with
states to facilitate LDP implementation by reviewing plans
and grant documents produced pursuant to the SEDM
Program and by reviewing data collection activities
involving the states. SEDM coordinators also will
encourage states to adhere to LDP requirements and
promote environmental data integration.
Environmental Services Departments -- These
departments provide technical services (e.g., laboratory
analyses, field personnel, etc.) to media programs within
the region, and frequently perform data collection or
contribute to planning activities associated with data
collection. The Environmental Services organization will
provide technical guidance and/or assistance to regional
media program personnel in complying with the LDP,
including use of GPS. Environmental Services personnel
will assure that locational data requirements are addressed
and met by all spatial data-generating activities.
OARM/National Data Processing Division (NDPD)
NDPD is responsible for overseeing the management and acquisition
of computing and other technological resources for EPA. The
endorsement of global positioning system technology to meet the goal
of 25 meter locational data accuracy may necessitate the development
of an Agency-wide plan to acquire certain equipment. NDPD will be
responsible for examining and documenting requirements for a
vehicle to obtain the necessary equipment, hardware, and software for
full and consistent use of global positioning system technology.
The Regional CIS Work Group
The Regional GIS Work Group is an organization of EPA professionals
convened to address issues concerning the application of spatial
analysis technology to environmental management. Members of the
Work Group include representatives from the ten EPA regional
offices, EMSL-Las Vegas, NDPD/OARM, and the Headquarters
National GIS Program. The interaction between the regional GIS
Work Group and the GIS user community is displayed in Exhibit 4-4.
The purpose of the Regional GIS Work Group is to establish a network
to identify regional-level issues to be addressed regarding
environmental data and spatial analysis; to exchange ideas, progress,
and experience; and to recommend activities that would increase the
value of spatial data to all environmental protection participants in
EPA, other Federal agencies, and states.
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Exhibit 4-4
Interaction between the Regional GIS Work Group
and the GIS User Community
Regional
GIS Work Group
Members
Ten EPA Regional offices
EMSL-Las Vegas
NDPD
OIRM
The
Public
Water
Program
aste
rogram
Federal
Multi-
Media
Pgms
\ S
3/92 LDPIG
4-12
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The Regional GIS Work Group has developed a five-part Strategic Plan
to ensure an effective and efficient GIS program and to promote spatial
data acquisition/application capabilities for all end users. Each of the
five components of the Strategic Plan is presented in Exhibit 4-5 along
with associated priority goals and objectives. A high priority of the
Regional GIS Work Group is to provide strategic direction and
leadership for implementing the Locational Data Policy at the regional
level.
Regional GPS Work Group
Another inter-regional group that will have an increasingly important
role in LDP implementation is the Regional GPS Work Group, formed
in conjunction with the Regional GIS Work Group. The purpose of
the GPS Work Group is to create a mechanism within EPA to identify,
present, and discuss GPS issues.
The GPS Work Group has performed many activities since its
inception in 1990. It has established a communication network for
Agency personnel interested in GPS technology through Agency
electronic mail and monthly conference calls. In addition, the Work
Group nominated GPS coordinators for all 10 regional offices to act as
regional contacts on GPS issues and to be responsible for regional cross-
program GPS implementation and coordination of GPS activities.
The Regional GPS Work Group has encouraged nomination of Agency
membership on the FGCC to allow EPA participation in inter-
governmental discussions of many GPS issues. The information
gathered from the FGCC is disseminated to the Work Group and to the
regional GPS community through the nominated coordinators. The
Regional GPS Work Group will provide valuable contacts to regional
and state LDP participants. Their role will become increasingly
valuable with the phase-in of GPS use.
Environmental Initiatives
Many interdisciplinary, inter-regional environmental initiatives have
begun in EPA. These initiatives are large, complex programs targeting
a specific environmental problem and approaches to solving it.
Examples of such environmental initiatives include the Great Lakes
National Program, the Chesapeake Bay Clean Up Program, and the
Environmental Monitoring and Assessment Program (EMAP).
These initiatives do not fall under the jurisdiction of a single media
program office or regional office but, instead, involve the coordination
of participants from many organizations including EPA regions, EPA
media programs, state agencies, other Federal Agencies, and often
3/92 LDPIG 4-13
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Exhibit 4-5
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Components, Goals, and Objectives of the
Regional GIS Work Group Strategic Plan
Component
Priority
Goals
Provide effective
management of
Regional GIS
Programs
Identify, acquire, and
manage priority data
bases necessary to
effectively meet the
Agency's spatial
analysis needs
Develop effective
spatial analysis and
data integration
tools
Enhance information
exchange and technical
transfer
Develop spatial analysis
and data integration
tools with broad
application to Agency
decision-making
processes.
Provide effective
coordination with
states, other Federal
agencies, and the public
Establish and maintain
effective mechanisms for
technical transfer of GIS
applications among all
government GIS users.
Strengthen the
State/EPA partnership
for spatial data
management
Provide
leadership to
enhance spatial
data quality
Acquire accurate
and precise
locational data for
facilities and
environmental
entities of interest
Specific
Objectives
Prepare and
implement an
Agency-wide
spatial data plan to
acquire and develop
priority spatial
databases.
Improve the
Agency's spatial
data management
infrastructure.
Focus spatial
analysis and data
integration tool
development efforts
to support
Region-wide and
Agency-wide
decision processes.
Promote and
encourage effective
documentation and
dissemination of
spatial analysis and
data integration tools
with broad
application within
the regions and the
Agency.
Enhance and support
opportunities for
information exchange
within the Agency, and
between the Agency the
states.
Provide effective
mechanisms to maintain
and disseminate spatial
analysis and data
integration tools with
wide application in the
Agency.
Develop and implement
Agency-wide standards
and conventions for
spatial data development,
exchange, and display.
Enhance telecomm-
unications infrastructure
to facilitate
communication between
EPA and states.
Coordiante closely with
the SEDM Program, and
support its expansion to
enhance integrated
information needs.
Emphasize media
program and other grant
processes to facilitate
the development of
effective, self-sustaining
state GIS and data
integration programs.
Establish and maintain
effective communi-
cation to enable direct
coordination with state
spatial data programs.
Develop mutually
compatible state and
regional GIS programs,
including hardware,
software, standards, and
data bases.
Establish
operational GPS
capability within
the regional offices.
Provide leadership
and guidance for the
implementation of
the LDP.
Establish locational |
data standards and
practices as part of
each national data
system.
Establish FINDS as I
the Agency's
principal repository |
for facility/source
locational data.
Focus efforts to
improve the quality |
of existing
locational data.
-------
times international governments. If the activities of these
environmental initiatives include generation of locationally-based data
(e.g., monitoring), those activities must comply with the requirements
of the LDP, including the collection and documentation of lat/long,
method, accuracy, and description. Further, they must encourage use
of GPS and an accuracy goal of 25m. If the activities under these
initiatives involve compilation of data from existing sources, initiative
managers must accept only locational data from other programs that
conforms to LDP requirements. In addition, implementation of these
initiatives should begin with development of LDP implementation
plans, similar to those prepared by media program offices, to ensure
that LDP requirements are planned for upon project initiation.
4.3.2 Media Program Offices
All managers of media programs within EPA play a crucial role in
implementing the Locational Data Policy. Full execution of this policy will
require changes in practices and routines for almost all program data
collection activities and will affect field personnel, program managers, and
data managers. It is through their combined efforts that EPA will realize the
substantial benefits of wide-scale LDP implementation.
Media Program responsibilities for LDP implementation include:
Production of Program LDP Implementation Plans -- Every
program will be responsible for laying out its plan to implement
the LDP, detailing all activities required to assure policy
requirements are met by all program participants, including
states other members of the regulated community (Chapter 6).
Development or redirection of existing data collection and
documentation policies and procedures to meet the
requirements of the LDP Standard procedures by which data
supporting a program's mission are generated may require
modification in order to assure LDP compliance. Program data
managers will be responsible for identifying procedures which
need to be modified to conform to the LDP and for
implementing necessary changes.
Implementation of changes to documentation tools, such as
survey forms, grant documentation, contracts, etc., to ensure
timely institution of the LDP Programs employ a variety of
tools by which information is collected, including routine
survey forms, electronic data submissions (on-line data access to
EPA data bases or submissions on tape or diskette), application
forms, notification forms, etc. Program managers will be
3/92 LDPIG 4-15
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responsible for identifying the tools that require modification for
implementing those changes.
Dissemination of instructions Program offices are responsible
for ensuring that adequate instructional material is included in
data collection instruments or users' manuals for LDP
compliance.
Provision of adequate resources OIRM can make some limited
resources available to programs for implementing the LDP (see
section 4.2.3), but program offices must also redirect resources, in
terms of personnel, funding, and equipment to meet the
requirements of the LDP. An explanation of the expected costs
and a plan for covering them should be included in the
program's LDP Implementation Plan. A process for estimating
resources for LDP implementation can be found in the Guide to
Selecting Latitude/Longitude Collection Methods.
Addressing LDP requirements in planning processes ~ Planning
documentation must be produced for a variety of EPA activities,
including program planning, site sampling, project planning,
and QA planning. Compliance with the LDP is a key element
which media program managers must now include in preparing
planning documents.
Coordination with the IRM Steering Committee to set priorities
for policy implementation -- Program managers must work
both with their program staff and the IRM Steering Committee
to develop a sensible approach to implementing the LDP in their
spatially-oriented projects, programs, and cooperative ventures.
This coordination may be accomplished in phases, each phase
may be prioritized according to various criteria such as need,
availability of resources, opportunity, etc.
Extension of the LDP to program personnel, agents, grantees,
delegates, and regulated community Senior program managers
must effectively institute compliance byconveying the Policy to
all other organizations, including states, other Federal agencies,
sub-programs, contractors, and the regulated community with
whom they are implementing their programs.
Development of DQOs for planning and waiver requests --
Program managers will develop DQOs when planning
information collections. In addition, the DQOs will be used as
the primary justification should a program wish to request a
waiver from any portion of the LDP.
3/92 LDPIG 4-16
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The success of any venture depends on the individuals who play a part in it.
Therefore, in addition to this discussion of program LDP implementation
responsibilities, the responsibilities of key individuals are presented below.
4.3.3 Individuals/Functions
Within each office in EPA, certain individuals hold functional
responsibilities that require them to be involved with LDP implementation.
The individuals responsible for the LDP, summarized in Exhibit 4-6, include:
Assistant Administrators, Associate Administrators, Regional
Administrators, Laboratory Directors, Managers of
Environmental Initiatives, and the General Counsel As stated
in the LDP, these individuals shall "establish procedures within
their respective organizations to ensure that information
collection and reporting systems under their direction are in
compliance with this Policy." Implementation of the LDP
within each program or environmental initiative is the ultimate
responsibility of its senior management. To acknowledge this
responsibility, these individuals will participate in the
development of LDP Implementation Plans with their staff to
obtain an organization-wide view of LDP compliance.
Senior Information Resources Management Officials (SIRMOs) -
- SIRMOs will serve as liaison between the programs and the
IRM Steering Committee, providing assistance to program
management and staff on meeting the requirements of the LDP
and developing Program LDP Implementation Plans. All
waiver applications for data collection efforts within the
program must be reviewed and endorsed by the SIRMO. Thus,
the SIRMO will work with program managers in reviewing data
quality objectives and formulating Program LDP
Implementation Plans and waiver requests, transmitting them
to the IRM Steering Committee, and ensuring the committee's
comments are addressed.
Program and Environmental Initiatives Managers Managers
of programs and environmental initiatives will be responsible
for developing LDP Implementation Plans. These individuals
will identify affected activities and collections, establish steps to
be taken to ensure compliance, and implement the necessary
procedures. Managers must convey requirements of the LDP to
all participants, including the regulated community, and ensure
that procedures are changed so that LDP compliance becomes a
3/92 LDPIG 4-17
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OJ
1
Exhibit 4-6
Individual Responsibilities Under the
Locational Data Policy
Individual/Function
Assistant Administrators, Associate
Administrators, Regional Administrators, ****
Laboratory Directors, and the General Counsel
Senior Information Resources Management
Officials (SIRMOs) """""
Managers of Programs and Environmental
Initiatives """1"
Data Base Managers
MM
Permit Writers mm
Site Managers «««
Field Investigators »MM
Compliance Monitors """
Responsibilities
Establish procedures within their organizations to
^^^ ensure that information collection and reporting
""""iP9*" systems are in compliance with the LDP; aggregate
Program LDP Implementation Plans into
organization-wide LDP Implementation Plan.
Serve as liaison with the IRM Steering Committee;
*m|p9»- provide implementation plan development to
programs; review and sign-off on waiver requests
Implement LDP within their programs or initiatives,
jn^ by identifying activities and relevant data
mHW^' collections; preparing Program LDP Imp. Plans and
waiver requests; endorsing use of GPS
Ensure data bases are modified so as to allow
M*|0)»»- inclusion of locational information and ensure
documentation is updated
Ensure that data required by LDP are collected and
MM&jjp*- documented during permit issuance and renewal
processes
_^^ Ensure that LDP requirements are addressed in any
"^^^ site planning and activities; ensure use of GPS
. Jh^ Ensure that required locational data are available for
^^ locations under investigation
.a^J^ Ensure that adequate locational data are available
^^^ for all monitoring sites
f"
_1
00
-------
part of their routine. If compliance with LDP requirements is
infeasible, program managers must work with program SIRMOs
to develop waiver requests based on DQOs.2 Program and
environmental initiative managers also must oversee the
incorporation of GPS technology into their data collection
processes.
Data Base Managers Data base managers (also referred to as
system managers) will be responsible for ensuring that data bases
are modified to hold the information defined by the LDP.
Activities include creating data elements to house the
information and edit checks to assure that the data are complete,
in the correct format, have documented accuracy, etc. Data base
managers also will be responsible for updating data entry
procedures and supporting documentation (such as users'
manuals, data entry manuals, data element dictionaries, training
curricula, etc.) to accommodate LDP requirements.
Permit Writers Permit writers will be responsible for ensuring
that data required by the LDP are collected and documented
during permit issuance and renewal. This may be achieved by
requiring that the regulated community supply appropriate
information on application forms, that coordinate information
be included on the permit itself, and/or that coordinates be
determined as part of a compliance schedule. Involvement of
permit staff should be spelled out clearly in the Program LDP
Implementation Plan.
Site Managers EPA personnel often will be responsible for
managing site activities (e.g., cleanup, etc.) performed by
contractors or state participants. Site managers should be certain
that LDP requirements are addressed in all site planning
documents, including contracts, cooperative agreements, QA
project plans, site sampling plans, remedial investigation/
feasibility studies, and other appropriate vehicles. Site managers
also will be responsible for ensuring that LDP requirements are
met during site activities, including the use of GPS technology.
field Personnel -- Field personnel, including inspectors,
technical consultants (e.g., hydrogeologists, engineers, etc.),
mobile lab operators, and others will be responsible for assuring
that the required locational identification data are available for
the locations on which they are working. Activities may
involve determining whether locational data already have been
^Waiver requests for environmental initiatives should be prepared with the assistance of the initiative team
member with responsibility for data management.
3/92 LDPIG 4-19
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collected, obtaining site access, and either verifying existing
locational data in the field or creating new location identification
data. Field investigators also will be responsible for transmitting
locational data (either new or renewed) to the appropriate office
personnel so that it can be recorded in a computerized data base,
site paper file, or other appropriate format.
Compliance Monitors Certain program personnel, who
operate either out of EPA headquarters or regional locations, are
responsible for receiving and reviewing compliance reports
submitted by the regulated community. These include
Maximum Contaminant Level violation reports under the
SOW A, emissions monitoring reports, RCRA ground water
monitoring well sampling reports, Superfund samples, ambient
and effluent water monitoring samples, process monitoring
samples, and other types of monitoring results. Compliance
monitors will be responsible for assuring the existence of
adequate location identification information for all monitoring
sites. Compliance monitors also will be responsible for
informing data generators of the requirements of the LDP and
assuring that this information is submitted to them. The details
of compliance monitoring should be a component of the LDP
Implementation Plan.
4.4 State, Indian Tribe, and Trust Territory
Delegates
As stated in Chapter 1, this Policy extends to all state delegates of Federal
environmental laws. This section outlines the expectations for state adoption of
mechanisms to ensure compliance with the LDP. Other organizations that are not
states, per se, including Indian Tribes and Trust Territories have a similar political
relationship to EPA, and will follow the same guidelines.
4.4.1 Variability of State LDP Responsibilities under Different
Types of Federal Environmental Laws3
States can be delegated authority by EPA for several major environmental
laws, including RCRA, SDWA, CWA, and CAA. When authorized, a state
will define its universe of regulated, monitored, and tracked entities under
criteria that are at least as stringent as those established by EPA. Therefore,
each authorized state will play a major role in determining those entities for
which LDP requirements must be met and in collecting LDP-required data for
them.
will defer to the states as the final authority in determining adequacy of location identification data when a
state has been delegated responsibilities for a Federal environmental program.
3/92 LDPIG 4-20
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There are other Federal environmental laws under which states may play a
corresponding role to EPA but are not authorized to implement in lieu of
EPA. Under these laws, such as "Superfund" (CERCLA/SARA), other types
of opportunities exist for states to address the requirements and goals of the
LDP.
In either case, the major responsibility for ensuring LDP compliance by states
will rest with the EPA managers or state managers of EPA mandated
programs and/or environmental initiatives. These individuals must
provide direction, guidelines, and/or assistance to their state counterparts in
meeting LDP requirements.4 Data integration to support risk reduction,
pollution prevention, and other components of EPA's strategic plan will be a
responsibility that program and environmental initiative managers must
uphold and share with their state partners. Definition of state roles will be a
key component of Program LDP Implementation Plans (Chapter 6).
Whenever states are responsible to report locationally-based data to EPA,
those data must comply with LDP requirements. This section presents the
different possible roles that states play hi Federal environmental laws and
environmental initiatives, and their significance to state responsibilities
under the LDP.
State-Authorized Programs
For Federal environmental programs delegated to states, the LDP
applies only to those regulated, monitored, and/or tracked entities that
meet criteria of Federal law. For those entities, states must collect and
document lat/long coordinates, method, accuracy, and description as
part of their routine reporting requirements to EPA. In addition,
pursuant to the goal of the LDP, the use of GPS and the attainment of
better than 25m accuracy is encouraged. Excluded are entities regulated,
monitored, and/or tracked by a state under more stringent state criteria.
For example, if the pound-per-year threshold above which an entity
must be regulated is lower in an authorized state than under the
corresponding Federal law, LDP requirements must be adhered to only
for those entities above the higher (i.e., Federal) threshold.
For those entities regulated, monitored, and/or tracked by a state but
not meeting the criteria of Federal environmental laws, state
adherence to LDP requirements is voluntary and encouraged.
Adherence to the LDP for these entities will streamline data
integration between other states and/or EPA. Such integration will
simplify the information transmission process, especially if the
requirements are changed and the entities later meet Federal criteria
and have to be reported on to EPA.
Mn some instances, states are host to EPA program pilots.
3/92 LDPIG 4-21
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The criteria that determine whether an entity is within the scope of a
Federal environmental law will be developed by EPA media program
offices. Similarly, the state authorization criteria also will be developed
by EPA media program offices. In their Program LDP Implementation
Plan, EPA media program offices will include the specifications for
reporting by authorized states to ensure LDP compliance in all
environmental data collections.
Environmental Programs Run by EPA
There are two cases for environmental programs being run by EPA and
not a state: (1) the program is not normally one that gets delegated to
states (e.g., CERCLA, TSCA, FIFRA, or an environmental initiative
such as the Chesapeake Bay Cleanup Program), or (2) the state has not
been granted authorization under a law that can be delegated (e.g.,
RCRA, SDWA, CWA, CAA). EPA lead on a federal environmental
program or initiative does not preclude states from meeting LDP
requirements when reporting locational data to EPA.
Collection and reporting of locational data by states to EPA under
Federal environmental law or under an inter-agency environmental
initiative can be arranged under a variety of mechanisms, including
cooperative agreements and grant stipulations (Sec. 4.4.3). Again, the
criteria that determine whether an entity is within the scope of a
Federal environmental law will be developed by EPA media program
offices. Similarly, the definition of state data reporting requirements,
and the mechanisms and vehicles by which to meet those
requirements, also will developed by EPA media program office or
environmental initiative managers. In their Program LDP
Implementation Plans, EPA media program office and environmental
initiative managers will address the specifications for reporting by
states for non-authorized programs or initiatives to ensure LDP
compliance in all environmental data collections.
Often, states will have their own environmental laws that correspond
to the Federal laws. For example, many states have their own
"Superfund" programs. Adoption of LDP requirements and guidelines
by these state-only programs is encouraged by EPA. State adherence to
LDP specifications will facilitate data integration among states and
between states and EPA, and may reduce the amount of data collection
that must be performed.
4.4.2 Reporting Requirements
The entities for which states must collect and document lat/long, method,
accuracy, and description have been defined above based upon the
relationship between the state and EPA for individual programs or
3/92 LDPIG 4-22
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initiatives. There are several possible mechanisms by which LDP-generated
data can be transferred to EPA, including state data entry into a major Federal
system and use of other reporting tools (forms, surveys, reports, etc.). The
ntechanism(s) to be used under each environmental program or initiative
must be identified in Program (or Initiative) LDP Implementation Plans.
Guidelines must be given to states on how to use them. For example,
redundant reporting of location identification data should be avoided.
Guidelines should be provided to states on when and how to submit LDP data
(e.g., lat/long may not have to be measured every time a DMR report is
submitted). These guidelines should be a component of the implementation
plan. The mechanisms for states to report LDP-generated data are discussed
below.
Data Entry into Federal Data Bases
Some states have elected to have direct data-entry access to certain EPA
data systems such as RCRIS, AIRS, STORET, and PCS. Data entry can
be either on-line or via electronic submission (i.e., tape or diskette).
EPA system managers must ensure that appropriate data elements are
in place within the data systems so that states can enter LDP-required
data. State data managers must ensure that the locational data
elements are populated for the system records of Federal data bases that
they are responsible to maintain.
"Tool" Submission
As discussed above, there are other tools (e.g., reports, surveys, and
forms) that are used to report state information to EPA. The aggregate
of all reports, surveys, forms, etc. submitted to EPA by states is
considered a "data collection" and, if locationally-based (i.e., about a
place), falls under the scope of the LDP. For all such tools used by states
to create a locationally-based EPA data collection, LDP requirements
must be fulfilled. EPA program or initiative managers will ensure that
the forms, surveys, reports, and other "tools" are modified to capture
the data required by the LDP from the state. They also will provide
guidance to states on how to meet LDP requirements if use of such
tools by states is optional. State participants are responsible to make
sure that the tools are filled out completely and accurately for LDP-
required data.
4.4.3 EPA Support to States for LDP Participation
States have the responsibility to comply with the LDP for data that they collect
for EPA. There are several types of EPA resources available to states so that
they may fulfill their responsibilities. These resources include:
3/92 LDPIG 4-23
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Grants -- Grants to states are available from program offices,
regional offices, and the SEDM program. In order for grants to be
directed towards providing assistance to states in meeting LDP
requirements, stipulations to that effect must be part of the grant.
States will be accountable to EPA for grants which include a
stipulation for adherence to the LDP.
Cooperative agreements -- Cooperative agreements are
commonly used to document the expectations of states and EPA
in environmental projects jointly undertaken. For example,
cooperative agreements are used in the "Superfund" program to
identify actions for those sites that are highest priority to states,
regardless of whether they meet Federal National Priority List
(NPL) criteria. Cooperative agreements can be used to specify
activities that will ensure LDP compliance by states, including
support that will come from EPA and/or error resolution
processes.
Loans EPA often provides loans to states to fulfill certain
mission requirements. For example, the State Revolving Fund
loan program has replaced the Construction Grants program
under CWA. Loan amounts and specifications could be created
to include the support necessary in meet ing LDP requirements.
Additionally, EPA regional offices can enter into a loan program
with their states for equipment such as GPS devices. This
arrangement may ensure that locational data submitted to EPA
by states are created using the GPS technique and meet the 25m
accuracy goal.
A description of the incentives for meeting LDP requirements by the LATF
can be found in Appendix A.
4.5 Designated Representatives
Chapter 1 defined all designated representatives of EPA (i.e., contractors, grantees,
and universities) as participants in the LDP. Those representatives will have the
same responsibilities as those offices within EPA who collect pertinent data or
contribute to relevant data bases. Language that requires adherence to Agency IRM
policies and standards is often a standard part of Agency contracts and grants.
Program LDP Implementation Plans should describe the means that programs will
use to ensure LDP compliance by designated representatives.
3/92 LDPIG 4-24
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Chapter 5
AGENCY-WIDE SCHEDULE
-------
5. AGENCY-WIDE SCHEDULE
Successful and consistent implementation of the Locational Data Policy requires
diligent coordination among EPA offices and outreach efforts to organizations
external to the Agency. In order for implementation to be completed within an
appropriate time frame, Agency-wide priorities and milestones for implementation
have been established. These priorities and milestones are discussed in this chapter.
Additionally, areas requiring coordination with other Federal agencies are
identified.
5.1 Schedule and Priorities
This section defines the general schedule and milestones for LDP implementation
and establishes priorities for certain activities. The milestones require action either
on the part of OIRM or the programs. These milestones and their sequence are
summarized in Exhibit 5-1.
5.1.1 Accuracy Goal
As discussed in Chapter 3, the Locational Accuracy Task Force recommended
that an accuracy goal of 25 meters be established for new data. The Agency-
wide goal is to have all locational data accurate to better than 25 meters by
December 31, 1995. The LATF also recommended that, beginning in 1992,
map interpolation be used to determine lat/longs with GPS being phased in
gradually. After 1995, GPS should be the principal method of collecting
locational data.
5.1.2 LDP Implementation Plans
The LDP calls for EPA managers to create implementation plans within their
programs. Assistant Administrators will coordinate all the plans produced
within their organization so that there is clear understanding of
responsibilities. The components of the plan (Chapter 6) include such items
as an estimate of the amount of information which^ must be collected and
documented, the necessary steps to be taken to fully implement the LDP,
estimates of time and resource requirements, and issues or constraints which
must be confronted. OIRM will review LDP Implementation Plans and will
pass their assessment of the plans to the IRM Steering Committee both to
ensure that LDP requirements are adequately addressed and to coordinate
LDP implementation Agency-wide. The plans should be completed and
submitted to OIRM for review by the end of the FY92 (September 30, 1992). At
that point, OIRM will review the implementation plans and confer with the
submittors to resolve any outstanding issues. The IRM Steering Committee
will give feedback to submitters of LDP Implementation Plans by December
1992.
3/92 LDPIG 5-1
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OJ
VO
K)
r
§
o
Exhibit 5-1
Agency-wide LDP Implementation Schedule
Legend
Finite =
Ongoing=
Date
Task
Jun30 Dec 31 Jun30 Dec 31 Jun30 Dec 31 Jun30 Dec 31 Jun 30 Dec 31 Jun 30 Dec 31
1990 1990 1991 1991 1992 1992 1993 1993 1994 1994 1995 1995
S"
K)
Recommendations for Locational Data Accuracy Goal (LATF)
Use of Map Interpolation and phase-in of GPS for >25M Accuracy
Use of Best Technology (probably GPS) and >25M Accuracy
Final LDP Implementation Guidance (O1RM/IMSD) »
Populate lat/long fields in FINDS (OIRM/PSD/ITIB/MIS) ::
Tools (contracts, forms, reports, etc.) Redesign (Programs, OPPE) ::
Program LDP Implementation Plans (Media Programs) -
System Redesign (OIRM, Media Programs) :
Completion of Pgm LDP Imp Plan Review (IRM Steering Committee):
Data Collection First Priority Systems (OIRM, Media Programs) ;
Data Collection Second Priority Systems (OIRM, Media Programs) ;
Data Collection Third Priority Systems (OIRM, Media Programs) :
Implementation of Systems Redesigns (Media Programs) ;
-------
5.1.3 Existing and Planned Systems
Many EPA data systems will require modification to house or use the
locational coordinates and qualifiers required by the LDP. Some systems, such
as STORET, can already accommodate some of the required information.
Other systems currently have no fields to house any of the LDP-required
information. It is critical that these data elements be included in
computerized data bases to enable secondary use based on location. Among
the first steps in LDP implementation is redesigning all existing and planned
data systems to accommodate required locational data in the formats
specified.
All modifications of existing and planned systems to accommodate lat/long
coordinates, method, accuracy, and description should be designed by
December 1992. See Chapter 2 for a discussion of EPA systems that fall under
the scope of this policy. Implementation of the redesigns should then
proceed as quickly as resources allow and be completed by December 31, 1995.
Details of the necessary modifications can be coordinated between OIRM and
the managers of individual program systems. In general, the types of changes
that might be made to systems to make them compatible with the
requirements of the LDP include:
Data element addition Creating new data elements for latitude,
longitude, method (including datum, and map scale, accuracy,
and description), accuracy, and description.
Data element formatting Creating or modifying the data
element fields to correctly house LDP data. Examples include
formatting coordinate component values to the correct length;
representing a decimal point in the correct place; allowing four
digits to the right of the decimal point, or allowing the storage of
a "+" or a "-" to indicate hemisphere.
Edit check addition Developing edit checks in the data entry
screens (or as part of the data base building process) to filter
impossible values or to verify coordinates based on other
locational information (e.g., validity of a lat/long pair verified by
comparison to state or county boundaries), or to check an entire
database in batch mode to flag "bad" data values for later
correction.
Functional capability development The development of
capabilities for users of locational data; examples include
searching within a geographic area, sorting by method, or
screening by accuracy.
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An explanation of needed/planned system modifications should be a
component of each program's LDP Implementation Plan (Chapter 6). The
computer system implications of the LDP are described more fully in
Chapter 8.
5.1.4 Historical Data
The Locational Data Policy requires that historical data collections (existing
data bases) eventually be populated with coordinate data for their locational
entities. Chapter 7 of this document discusses updating options for historical
data. General priorities for historical locational data were given in Chapter 2
and reiterated below:
Data collections with geographic coordinates other than lat/long
are of the highest priority for revision.
Data collections with lat/long coordinates defining the locations
of their entities but incomplete or missing lat/long qualifiers are
of second priority.
Data collections with no geographic coordinate data are of third
priority but must comply with the LDP by the end of 1995.
LDP Implementation Plans should address the schedule for updating
historical data bases. In general, first priority data collections (those with
location data in another coordinate system) will be made to comply with the
information requirements of the LDP by the end of December 1992. Second-
priority data collections (those in which lat/long metadata elements are
missing or incomplete) will be updated to meet LDP data requirements by the
end of December 1993. Third-priority data collections (those with no
geographic coordinate data) will be brought into full compliance with the LDP
by the end of December 1995. By the end of calendar year 1995, all office-
created locational coordinate data (i.e., those produced by methods including
address matching, zip code, centroid, etc.) should be replaced with more
accurate field-collected coordinate data obtained using GPS.
5.1.5 Form and Contract (Tool) Modifications
There are many types of documents that program managers use as tools to
collect the data needed to accomplish mission objectives. Many of these
documents can be used to meet LDP requirements. These documents include:
Notification forms (e.g., RCRA Form 8700-12).
Application forms (e.g., NPDES Forms 1, 2c).
Survey forms (e.g., RCRA biennial survey forms).
3/92 LDPIG 5-4
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Standard reporting forms (e.g., TRI Form R).
Contracts (e.g., with RAC contractors for site cleanup).
Grant documentation (e.g., for State/EPA grant monies).
Cooperative agreements (e.g., for EPA-State Superfund cleanup
prioritization).
Memoranda of understanding.
Pre-formatted diskette data collection tools (e.g., for the Water
Body System).
New lat/long data will be collected in many programs to meet the
requirements of the LDP. Where lat/long already are being collected,
locational metadata (method, accuracy, and description) must become part of
the data collection routine. Therefore, the tools for information collection
must be modified to assure LDP requirements are met.
Modification of data collection tools must be coordinated with data system
redesign efforts and should occur prior to collection of missing data. The
tools used to collect data for high priority systems similarly should be given
highest priority for redesign. All data collection tool redesign efforts should
be completed by the end of March 1993. The plans, steps, and schedule for
data collection tool redesign should be documented in each LDP
Implementation Plan. In addition, LDP Implementation Plans should
describe instructions to be given for providing locational data on the forms.
Locational data may not need to be collected or submitted repeatedly with
each form or report submission. The times and frequency of LDP data
collection should be clearly identified on the forms and in the plan.
5.1.6 Role of FINDS
A final step in LDP implementation is populating coordinate fields in FINDS.
This activity will be accomplished by a combination of address matching and
capturing locational data from program systems. FINDS will serve as the
information utility for providing facility locational information to the
environmental community and the public. OIRM currently is undertaking
an effort to modernize FINDS. One component of FINDS modernization is
to include lat/long coordinates in each facility record. Steps to include
locational data in FINDS will include:
Creating lat/longs for the "facility in general" in the FINDS
"master records" by address matching with corresponding
records in the Dun & Bradstreet File, resulting in one set of
coordinates per facility.
3/92 LDPIG 5-5
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Creating data element fields in the "alias records" of each facility
to capture lat/longs from program systems if they are available,
enabling a degree of tiering within FINDS.
The FINDS address matching project to populate the master record is
scheduled for completion by June 1992. Population of lat/longs in the alias
files will begin with synchronized updates. The specifications for performing
synchronized updates for the highest priority national systems will be
completed by April 19921.
5.2 Coordination with Other Federal Agencies
Implementing the Locational Data Policy requires coordination with other Federal
agencies that have expertise and responsibilities for spatial data. Agencies that deal
with information collection issues also will be included, y Coordination between
OMB, the FGDC, and the FGCC is especially important. Interaction between all
involved agencies should occur through a centralized point, rather than through
each office or program. Appropriate coordination points are described below.
5.2.1 Office of Management and Budget (OMB)
Under the Paperwork Reduction Act, OMB clearance is required when
information is to be collected by the Federal government from more than
nine non-Federal entities. The clearance process involves preparing and
submitting a formal Information Collection Request (ICR), to justify the
collection effort, describe the costs involved, and analyze the burden on the
regulated community. The Office of Policy, Planning, and Evaluation (OPPE)
within EPA provides the interface between OMB and the respective Agency
offices by reviewing ICRs prepared by individual programs and
environmental initiatives.
5.2.2 Federal Geographic Data Committee (FGDC)
The Federal Geographic Data Committee (FGDC) is an interagency committee
chaired by the Department of the Interior. It is responsible for coordinating
Federal digital cartographic and GIS activities and for establishing standards
and specifications for digital cartographic data. EPA coordinates with the
FGDC to ensure Agency compliance with these standards and to provide
input into the Committee's decisions. Participation in this committee
ensures EPA awareness of relevant activities in other agencies and to
coordinate with these agencies where appropriate. OIRM's National GIS
Program acts as EPA's contact with the FGDC. Under the LDP,
*As planned in the 11/91 Facility Identification Data Standard Implementation Plan (FIDSIP)
3/92 LDPIG 5-6
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"EPA is committed to implementing its locational policy in accordance
with the requirements specified by the Federal Interagency
Coordinating Committee for Digital Cartography (FICCDC)."2
5.2.3 Federal Geodetic Control Committee (FGCC)
The FGCC, is a component of the Department of Commerce, and is
responsible for national geodetic control surveys and datum. The transition
from NAD27 to NAD83 requires coordination with the FGCC. OIRM's
National GIS Program has appointed a representative to the FGCC for the
Agency.
^Recently renamed the Federal Geographic Data Committee (FGDC) Circular A-16
3/92 LDPIG 5-7
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A v. -.-.\^\w.^^^\\^vs.-.v.-,vf\v,y^v^^
* x ^»*»w»»fr»»*:^x«oK»»«*xft^^^
Chapter 6
LDP IMPLEMENTATION PLANS
-------
6. LDP IMPLEMENTATION PLANS FOR
PROGRAMS AND ENVIRONMENTAL
INITIATIVES
Implementation of the Locational Data Policy must be carefully planned so that it is
effective. This document describes the overall Agency plan for implementing the
LDP. EPA media programs and relevant data collection projects (such as the major
environmental initiatives) must develop detailed plans for carrying out the LDP.
For the purposes of LDP implementation, "media programs" are those responsible
for implementing an environmental law. Therefore, media programs are "offices"
that implement one or more of the laws such as RCRA, TSCA, CERCLA, CWA,
CAA, FIFRA, SDWA, and other environmental laws. In some cases, media
programs are divided into several sub-programs (e.g., Office of Water implements
NPDES and oversees non-point source pollution projects). All sub-programs must
be addressed in the implementation plan of each office. Similarly, environmental
initiatives are joint-organizational, cross-media projects that do not fall under the
jurisdiction of one media program.
LDP Implementation Plans prepared for EPA media programs and environmental
initiatives will accomplish the following:
They will give programs the opportunity to identify and anticipate all
the steps needed to meet the requirements of the LDP.
They will give the IRM Steering Committee the information needed to
coordinate LDP implementation Agency-wide.
One very useful tool for planning implementation of the LDP within a program
involves preparing Data Quality Objectives (DQOs) for the data collection efforts.
EPA Order 5360.1, "Policy and Program Requirements to Implement the Quality
Assurance Program" documents EPA's commitment to careful planning to ensure
that data meet the needs for which they are collected. The resulting EPA Quality
Assurance Program has developed a process built upon DQOs. Because locational
data are an essential part of measurement data, DQOs should be prepared with
locational data explicitly addressed.
DQOs currently require planners to define the level of data quality in terms of
primary data use. Under the LDP, however, likely secondary uses also must be
considered. These considerations may affect the definition of data quality.
After the quality objectives are defined, plans must be developed to assure
attainment of them. These plans and the DQO process should be included in each
program and initiative's LDP Implementation Plan. DQOs will help
implementation in the following manner:
3/92 LDPIG 6-1
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DQOs will help data managers determine the exact level of accuracy
needed for their locational data (the LDP strives toward a minimum
accuracy of 25 meters).
By knowing the level of accuracy needed, program managers can select
appropriate methods for locational data collection.
By determining the necessary locational data accuracy and appropriate
methods, other plan components (e.g., steps-to-achieve and roles and
responsibilities) may be defined.
Should it be necessary to apply for a waiver for any of the provisions of the
Locational Data Policy, DQOs will be the tool that programs use to justify their
waivers. The IRM Steering Committee will rely heavily on the DQOs when
reaching a decision on the waiver application.
The Quality Assurance Management Staff within the Office of Research and
Development can provide guidance and tools for the DQO process. DQOs should be
a part of every media program's plans for locational data collection and
documentation.
The remainder of this chapter discusses the development of LDP Implementation
Plans. It approaches these plans both in terms of their components and the process
for their development. Components of LDP Implementation Plans are summarized
in Exhibit 6-1.
6.1 Components of LDP Implementation Plans
Many decisions must be made by media program and data managers on how to
implement the LDP in their organizations. Each of those decisions should be
documented as a component of the LDP Implementation Plan. For each
component, responsibilities must be assigned, a budget must be identified, and a
schedule must be defined. If, upon developing a program LDP Implementation
Plan, it is determined that some LDP requirement(s) cannot be met, then a waiver
must be sought. This section discusses the components expected to be in each plan.
An example of a table of contents for a LDP Implementation Plan is displayed in
Exhibit 6-2.
6.1.1 Identification of Entities to which the LDP Applies
One of the first determinations program managers must make is which
entities in that program require locational data under the LDP. Chapter 2 of
this document identifies the types of entities for which location identification
data should be collected and documented. Exact determination of the entities
to which the LDP applies must be documented in the LDP Implementation
3/92 LDPIG 6-2
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Plans. This determination should be linked to DQOs based on the type of
other non-locational data associated with the respective entities.
6.1.2 Definition of Activities During Which LDP Data Will Be
Collected
There are many opportunities when location identification data can be
collected. These opportunities can be divided into two categories:
Activities during which entity location data MUST be collected
and documented.
Activities during which entity location data CAN be collected
and documented.
Activities during which location identification data MUST be collected and
documented should be identified in LDP Implementation Plans. These
activities will usually occur while generating new entity identification data
(i.e., data for that entity do not yet exist). Such activities might include
notifications, applications, or sample plan development.
Activities during which location identification data CAN be collected also
should be identified in the LDP Implementation Plan. These activities are
usually those that offer the opportunity either to double-check the quality of
existing locational data or to provide missing data, such as locational accuracy.
Such activities could include inspections or routine emissions reporting. If
gaining site entry may be a problem, an approach to overcome this obstacle
should be described in this plan. If acquisition of location identification data
is a component of a "technology transfer and data sharing" arrangement with
another organization such as a state, this relationship and the requirements
of the LDP should be explained and formalized.
6.1.3 Enhancements to Data Bases and Systems
Computerized data bases are usually the eventual destination of most data
that EPA and its agents collect. Chapter 2 of this Guidance Document
contains a discussion of the types of data bases affected by the LDP. In their
LDP Implementation Plans, data managers must list explicitly the data bases
maintained by or for their programs that will be affected by the LDP (i.e.r those
that need data element modification, the addition of coordinate data, or other
changes), further, data managers must state how the data bases will be
manipulated/modified to comply with the LDP. When addressing data
bases/systems in the LDP Implementation Plan, the following items should
be included:
3/92 LDPIG 6-3
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Exhibit 6-1
Co
vo
N)
LDP Implementation Plan Summary
Component
Description
Entity identification
Data collection activities
Data base/system enhancements
Tool redevelopment
Format of LDP-required data
Methods
Roles and responsibilities
Resources/Priorities
Quality assurance
Constraints
States
All entities regulated, tracked, monitored, etc., by program for which
locational identification data must be collected and documented, along
with the DQOs for the locational data
Each activity for which LDP compliance (i.e., collection and
documentation of location identification data) will occur
Modifications necessary to systems/data bases for compliance with the
LDP (e.g., new data elements, edit checks, etc.)
Modifications necessary to data collection instruments (e.g., application
forms or reports used to capture LDP data)
Specifications for each type of entity location data (i.e., whether the
entity is represented by a point, line, or area, etc.)
Methods for data collection/conversion to be used by program to comply
with LDP, by entity or activity if appropriate
The roles and responsibilities of program implementors in complying
with LDP, including EPA, states, etc.
Estimates of expected costs of LDP compliance within program, and
identification of potential funding sources and implementation priorities
Quality assurance measures to be adopted to assure adequate quality of
locational data, such as edit checks, double-checks, etc.
Anticipated restrictions or limitations, and approaches for overcoming
them to comply with LDP.
Reporting requirements and processes, resource availability
-------
The data bases/collections in which locational data will reside,
including the following information:
The purpose of the data base system.
- The type of locational data already present in the data
collection.
The numbers of entities requiring locational data (on an
existing- and new-per-year basis) and the percentage of
them already satisfying LDP requirements.
- Changes (including an estimate of costs to make changes,
and sources of funding) that are necessary to the data
base/system to accommodate the required LDP data, such
as:
Data system redesign (e.g., new data elements or
edit checks).
Data acquisition (e.g., automated interface to other
data bases or incremental field collection).
»
Centralized solutions (Chapter 7) to be used to meet LDP
requirements.
Incremental solutions (Chapter 7) to be used to meet LDP
requirements.
Automated and/or manual mechanisms for error
detection and correction.
Priorities assigned to data bases/systems for conformance to the
IDP.
Excluded data bases (i.e., those for which waivers will be
requested) and reasoning for exclusion of data collections to
which data managers feel that the LDP does not apply.
Computer system implications of the LDP are discussed in more detail in
Chapter 8.
6.1.4 Tool Redevelopment for Collecting and Documenting
Locational Data
A discussion of the many tools used by EPA programs to collect and/or
require necessary information was presented in Chapter 2. Such tools include
application forms and memoranda of understanding.
3/92 LDPIG 6-5
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Exhibit 6-2
Example of Table of Contents for
LDP Impelmentation Plan*
TABLE OF CONTENTS
1. Entity Identification
1.1 Documentation of the size of entity universe
12 Determination of the number of entities already in compliance with the LDP
1.3 Identification of all entities for which lat/long data must be collected/documented
2. Activity Identification
2.1 Definition of activities during which location identification data should routinely be collected
22 Definition of opportunities for incremental data collection (e.g., inspections)
3. System Modification and Software Acquisition Needs
3.1 Identification of systems to which the LDP applies
32 Determination of presence of needed data elements in key data systems
3.3 Comparison of program system data elements and formats to LDP requirements
3.4 Identification of other needed modifications and determination of plans, costs, etc.
3.5 Recommendations for edit checks or other error detection mechanisms
3.6 Identification of "functionality" of LDP data elements to ensure value to secondary users
3.7 Identification of systems to be excluded from the LDP, and waiver request plan
3.8 Determination of what level facilities and their sub-portions should be represented in
FINDS
3.9 Determination of methods, and costs to acquire/convert data to LDP format
4. Tool Redevelopment Needs
4.1 Identification of forms, reports, surveys, etc. that apply to the LDP
4.2 Determination of adequacy of each tool to meet LDP requirements
4.3 Definition of steps needed to make changes to each applicable tool
4.4 Determination of implications of change
4.5 Recommendations for a process to notify regulated community of locational data requirements
4.6 Suggestions for linking tools, activities, or systems to reduce redundancy for capturing data
5. Standard Way of Locationally Representing Each Entity (e.g., point, line)
5.1 Examination of the range of entity types to recommend how each type should be represented
52 Determination of amount/type/audience for needed guidance/revision of locational definition
5.3 Definition of format for location data (e.g., to how many decimal places)
5.4 Assesment of burden hour requirements
5.5 Identification of document requirements
5.6 Definition of facility representation
5.7 Determination of whether date and source should be part of locational data documentation
5.8 Definition of datum used and whether conversion to NAD 83 is necessary
5.9 Determination of circumstances under which data might deviate from 25 m accuracy goal
6. Location Identification Determination Method
6.1 Recommended method(s) to collect coordinate data based on data, entity, activity, etc.
6.2 Documentation of status of/requirementss for use of selected method
Continued on next page
May be modified upon development of LDP Implementation Plan Template
3/92 LDPIG 6-6
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Exhibit 6-2
Example of Table of Contents for
LDP Impelmentation Plan*
(continued)
TABLE OF CONTENTS
7. Role/Responsibility Identification
7.1 Definition of planning responsibilities; identification of key participants
7.2 Identification of responsibilities for quality control
7.3 Documentation of budgetary commitments on the part of all participants
7.4 Definition of reporting requirements/responsibilities
7.5 Definition of a process for interfacing (e.g., between states and Federal program staff)
7.6 Identification of responsibilities for system redesign work
7.7 Determination of plans/guidance/budgets/standards which must be developed and implemented
7.8 Determination of responsibilities for collecting location idetification data within a program
7.9 Responsibilities for transmitting location identification data to EPA data bases
8. Costs and Funding Sources, Priority of Activities, Steps to Complete, Schedule
8.1 Determination of feasible incentives that could be put toward states
8.2 Identification of grants to assist states/agents implement the LDP
8.3 Estimation of the costs of system redesign(s)
8.4 Estimation of costs of data acquisition to comply with the LDP
8.5 Priority list of activities to be funded first in case of competing resources
8.6 Estimation of the amount of equipment needed and costs related to purchase, distribution, etc.
9. Quality Assurance
9.1 Process for QA/QC, including edit checks and double-checks against other references
9.2 Definition of responsibilities for QA, including error resolution
9.3 Review of DQOs to assure that capture of location idetification information is addressed
9.4 Review of QA plans to ensure LDP requirements are addressed
10. Constraints
10.1 Identification of possible impediments or dependencies to full-scale implementation of the LDP
10.2 Recommendations to address identified constraints
May be modified upon development of LDP Implementation Plan Template
6-7
-------
Other data collection and documentation tools also may apply. These tools
may be in paper or electronic form, such as diskette or tape. The LDP
Implementation Plan must identify the tools used to collect data, whether any
changes will be needed to comply with the LDP, and how those changes will
be made. Changes to these tools may require notification in the Federal
Register or coordination with OPPE or OMB. Sometimes these tools may be
part of an information exchange program with state or local governments.
All modifications and steps to accomplish them should be made clear in the
LDP Implementation Plans.
OIRM briefly studied the forms listed in the April 198£ EPA Forms Catalog to
determine a partial listing of candidate forms which might require changes to
comply with the Locational Data Policy. The methodology of the study was
as follows:
Forms that might be relevant to the Loca'tional Data Policy were
identified by reviewing the titles of the 637 EPA forms found in
the EPA Forms Catalog.
Each form was examined to determine those that already
contained relevant locational information, such as address,
lat/long, etc.
The information on each form was reviewed to determine
whether LDP information is currently missing.
The percentage breakdown of the forms is presented in Exhibit 6-3. Of the 637
forms listed in the EPA Forms Catalog, 59% were eliminated from review
based on their titles. The remaining 262 forms were examined to determine if
they contain relevant locational information. Fifty-eight (9.3%) of the 262
forms were found to have a significant spatial data component. These forms
were then examined to determine the extent to which they already comply
with the LDP requirements.
The list of these relevant forms is presented by program in Appendix C.
These forms may need modification to ensure that sufficient/appropriate
information is collected in compliance with the LDP. It may be possible,
however, for a program to link computer systems to obtain the necessary
locational information, thereby reducing the number of forms on which, or
the number of times when, locational data must be collected. The
implementation plan of each program or environmental initiative must
describe an approach to ensuring that the proper locational information is
included on the appropriate forms.
3/92 LDPIG 6-8
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6.1.5 The Format of LDP-Required Data
Data managers must define specifications for each type of locational data.
This definition will include a description of:
Whether the entity location will be represented by a point, line
or polygon, including whether a specific point (e.g., the "front
door," the "driveway," or the "facility centroid") will be used to
represent what is actually an area.
To how many decimal places the locational coordinates will be
documented.
Whether source and date will be collected and documented.
How the NAD83 requirement will be fulfilled.
Whether the level of locational accuracy will be a deviation
from the 25 meter goal, and thus, require a waiver request.
Specification of the exact form of locational data will allow data managers to
evaluate whether those data will adequately support their missions and/or
secondary use.
6.1.6 Identification of Methods to be Employed
LDP Implementation Plans should include a discussion of locational data
collection methods being considered by the program to meet LDP
requirements. In developing these plans, program managers may decide that
certain methods are appropriate for certain situations. For example,
conversion software may be adequate to provide missing locational data in
existing data records but Global Positioning Systems may be used in the field
for new data collection. Eventually, all locational data should have similar or
better accuracy than that which can be obtained by using GPS.
Chapter 7 of this LDP Guidance and the Guide to Selecting
Latitude/Longitude Collection Methods present an introduction to some of
the methods available for locational data collection and conversion. Each is
addressed in terms of the expected costs and ranges of accuracy. Several EPA
technical resources, including EMSL-Las Vegas, the National GIS Program,
and the Regional GPS Work Group can provide more assistance in method
selection. Beginning in 1992, use of GPS should be phased in and so indicated
in the LDP implementation Plan. A primer on GPS use accompanies this
guidance package.
3/92 LDPIG 6-9
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Exhibit 6-3
Review of the 637 Forms in the EPA Forms Catalog
tn
Legend
Forms that were reviewed and
found relevant (58 forms)
Forms that were reviewed and
found irrelevant [no spatial
component] (204 forms)
Forms that were not reviewed based
on their titles [no spatial
component] (375 forms)
Total forms = 637 forms
:* :-
-------
6.1.7 Definition of Roles and Responsibilities
Implementing the LDP within a program requires coordination of many
involved parties. Thus, it is important that roles and responsibilities be
clearly assigned in the LDP Implementation Plans. Roles and responsibilities
should be defined for:
EPA/HQ and Regional program personnel.
State participants.
Other government organizations (e.g., DOE, COE, USGS).
The SIRMO.
EPA/HQ and Regional personnel other than those in the
immediate program.
Contractors.
f
Grantees.
Universities.
The regulated community.
Any participant not listed above, but who could play a key role in program
implementation of the LDP, should be identified as well.
6.1.8 Resources/Priorities
Adequate commitment of resources is one of the most critical factors upon
which successful implementation of the LDP depends. Resource availability
must be dearly planned because it affects implementation schedule and scope.
Because resources are limited, implementation priorities and associated
resource use should be defined in the LDP Implementation Plans. The LDP
Implementation Plans must address resources in terms of a cost estimate of
LDP implementation including both for initial and recurring costs.
Collaboration with other programs or environmental initiatives for
collecting LDP-required data might be considered during plan development as
a way to reduce costs.
The Guide to Selecting Latitude/Longitude Collection Methods describes a
process for estimating a budget for locational data collection. Chapter 4 and
Appendix A of this document identify resources that can be made available to
media programs.
3/92 LDPIG 6-11
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6.1.9 Quality Assurance Measures
Another key component of LDP Implementation Plans is the presentation of
an approach to quality assurance of locational data. Quality assurance can be
implemented in several ways, ranging from repeated collection of locational
data for the same entity, to edit checks on computer system data entry screens.
Managers of programs and environmental initiatives must design and
describe a plan to address quality assurance of locational data, including
identification of measures to be taken and responsible personnel. Adherence
to quality assurance plans will ensure that locational data achieve the level of
quality needed to meet their intended application.
6.1.10 Constraints
Managers of programs and environmental initiatives will face obstacles in
implementing the LDP. These obstacles may be in the form of delays,
resource limitations, regulatory authority, or dependence on other
organizations or events. In their LDP Implementation Plans managers of
programs and environmental initiatives must identify the expected
constraints that will be confronted, and present an approach for addressing
them.
6.1.11 State Roles and Responsibilities
EPA will rely on states for the generation, collection, documentation, and
submission of much of its locational data. States will rely on EPA for
guidance and assistance in meeting this responsibility. Section 4.4 identifies
the responsibilities states will have under the LDP. The specific activities to
ensure state compliance with the LDP must be documented in the LDP
Implementation Plans of all media programs and environmental initiatives.
Topics to be addressed include:
State reporting requirements under the LDP, including activities
during which states must meet LDP requirements (e.g., report
submission)
Coordination of data collection and reporting activities to avoid
redundant locational data collection by states
Establishment of a process for resolution of errors in locational
data submitted to EPA, and other procedural guidelines that
might be necessary to enable state adherence in the LDP
Resources (grants, equipment loans, etc.) to be applied towards
state adoption of the LDP.
3/92 LDPIG 6-12
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Assignment of state responsibilities under the LDP may depend on whether a
state has been delegated authority for a particular Federal law. LDP
Implementation Plans may have to address separate circumstances for
delegated and non-delegated states.
6.2 Process for Developing LDP Implementation
Plans
Chapter 4 of this LDPG specified that LDP Implementation Plans are to be completed
and submitted to OIRM for review by June 1992. OIRM will work with the IRM
Steering Committee and the submitters to review and finalize their plans by the end
of September 1992. OIRM offers the following suggestions for the process for
developing their LDP Implementation Plans.
6.2.1 Coordination of Steps to Achieve
By compiling the components of the LDP Implementation Plan as described
previously, managers will identify essential steps. Execution of these steps
must be coordinated so that LDP implementation progresses as smoothly as
possible within each program or environmental initiative. A proposed table
of contents for a LDP Implementation Plan was presented in Exhibit 6-2.
OIRM also offers workshops on creating LDP Implementation Plans.
6.2.2 Phasing
Managers of programs or environmental initiatives may find it beneficial to
phase-in implementation of the LDP. For example, certain entities, data
collections, or processes may be targeted for conforming to the LDP first,
others second, and still others third. The defined sequence of events and
phases should be part of the LDP Implementation Plan. If the steps to be
taken or the phases to be implemented do not conform to the Agency-wide
plan in this document (for example because of the time needed to coordinate
state activities) a waiver should be sought.
3/92 LDPIG 6-13
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Chapter 7
DATA CONVERSION AND COLLECTION METHODS
X*>:X«*aM-K-:-»M«-J««*i»K-:«^^
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7. DATA CONVERSION AND COLLECTION
METHODS
In complying with EPA's Locational Data Policy, program and initiative managers
will have to decide whether to convert old locational data to new formats, collect
entirely new locational data, or use a combination of conversion and collection
methods. The guidance presented in this chapter and the accompanying Guide to
Selecting Latitude/Longitude Collection Methods is intended to introduce the array
of available locational data conversion and collection methods and to assist in
selecting an appropriate method based on needs, accuracy, and available resources.
More detailed information on data conversion and collection methods can be
obtained from EPA's CIS Program and from the Office of Research and
Development (ORD). Guidance on the use of GPS technology can be found in the
GPS Primer which also accompanies this document.
A key concept to be introduced in this chapter is the idea of geocoding. The Guide to
Selecting Latitude/Longitude Collection Methods defines geocoding as the
"application of procedures, techniques, and technologies for the purpose of
identifying and documenting the geographic location of an entity." Therefore,
collecting new data is an integral part of the geocoding process. In contrast,
converting old data is not considered to be "geocoding." Data collection (i.e.,
geocoding) must precede conversion.
7.1 Centralized vs. Incremental Data Conversion
and Collection
The Guide to Selecting Latitude/Longitude Collection Methods discusses two
distinct approaches to data conversion and collection: centralized and incremental.
These "approaches" are the "institutional" ways of fulfilling LDP requirements.
The centralized approach is the process of converting or collecting all the needed
locational data at once. An example of centralized data collection is the creation of
lat/long coordinates for an entire data base of facilities by using address matching
software to convert facility addresses to lat/long coordinates. This approach is being
used for conversion and creation of locational coordinate data for facilities in EPA's
FINDS data base.
The incremental approach involves collection of new, or replacement of existing
locational data over time, by measuring lat/long coordinates during routine
activities such as inspections or surveys. Incremental collection of locational data
becomes an additional function of field personnel. Routine data collection or
update activities become opportunities for these personnel to create new, or
improve existing, location identification data.
3/92 LDPIG 7-1
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The principle differences between the two approaches lie in the time and dollars
required to collect all the necessary data (a relatively short, intensive effort for the
centralized approach vs a long term, gradual effort for the incremental approach).
The differences between the approaches are summarized in Exhibit 7-1. Note that
there is probably a continuum of tradeoffs between incremental and centralized
conversion and collection techniques.
7.2 Conversion Methods
Data conversion is a method of creating lat/long coordinates from location
identification data in another format. Although it may avoid the cost of new data
collection, it may incur the possible "cost" of accuracy loss. This section describes
methods available for converting from:
Non-coordinate locational information, such as address or ZIP code, to
latitude/longitude.
A different geodetic coordinate system to latitude/longitude.
One datum to anothef.
Of these, only the conversion of non-coordinate data is a true "geocoding" method.
The others, instead of creating geodetic coordinates, convert them form one format
to another. Under each of the three categories this section describes, appropriate
process, levels of expertise, limitations, expected accuracies, and relative costs.
Additionally, general guidance is provided on the assistance available for each
conversion method and on method selection. A process for determining a suitable
geocoding method is presented in the Guide to Selecting Latitude/Longitude
Collection Methods. A comparison of locational data conversion methods is
provided in Exhibit 7-2.
§
7.2.1 Conversion from Non-Coordinate Geopolitical Locational
Information to Latitude/Longitude
Two primary methods exist for converting from geopolitical locational data to
latitude and longitude. These methods are address matching and ZIP code
centroid.
Address Matching
Automated conversion from address information to latitude and
longitude is commonly referred to as "address matching." Address
matching uses digitized street data to match an entity's address to the
3/92 LDPIG 7-2
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OJ
!S
s
8
Exhibit 7-1
Incremental vs. Centralized Data Conversion and Collection
OJ
INCREMENTAL
Converting existing location
identification data in records
of data base one-by-one, over
time
Collecting new (or double-
checking existing) locational
data by using the field
opportunity of other routine
activities (e.g., inspections)
CENTRALIZED
Conducting an effort
specifically to convert
existing locational data of an
entire data base to
LDP-appropriate format all
at once
Gathering new locational
data for an entire data
base or network of entities
all at once
-------
U)
to
§
O
Exhibit 7-2
Comparison of Locational Data Conversion Methods
Method/
Characteristic
Description
Entity Type
Accuracy
Cost/Point
Required
Expertise
Manual
Effort
Limitations
Approach
Address
Matching
Converts front address
to latitude/longitude
through matching of
address to nearest
street section and
interpolating
Any entity with an
address
50-100 meters
$7-$30/Point
Requires no special
expertise process
automated
Requires little manual
effort - process is a
computerized batch
operation
Street data avail for
only 350 urban areas
Errors result from
non-standard spellings,
abbreviations
Point sources not
accurately represented
by address
Centralized
Zip Code Centroid
Assigns coordinates
based on ZIP Code
centroid to entity within
ZIP code
Any entity with a ZIP
Ranees from 100-500 m
in urban areas to many
km in rural areas
$.05-$5.00/Point
Requires no special
expertise - process
automated
Requires little manual
effort - process is a
computerized batch
operation
Accuracy varies with
geographical size of ZIP
Code
Point sources not
accurately represented
by ZIP Code
Centralized
ARC/INFO
Converts from one
coordinate system to
another through the use
of algorithms
Any entity which has a
geodetic coordinate
assignment
Accuracy of original
coordinates is
maintained
n/a
Requires no special
expertise - process
automated
Requires little manual
effort - process is a
computerized batch
operation
Does not perform
datum conversions
Centralized
GCTP
Converts from one
coordinate system to
another through the use
of algorithms
Any entity which has a
datum assignment
Accuracy of original
coordinates is
maintained
n/a
Requires no special
expertise - process
automated
Requires little manual
effort - process is a
computerized batch
operation
Limited to batch
conversions on PC
data files
Centralized
NADCON/
CDATUM
Converts from one
datumto another
through modeling
datum shift information
and interpolating.
CDATUM used for
ARC/INFO. NADCON
used for ASCII
Any entity which has a
datum assignment
Conversion accuracy of
15cm for conterminous
US and l.OM for other
areas
n/a
Requires no special
expertise - process
automated
Requires little manual
effort - process is a
computerized batch
operation
Degradation of
accuracy in remote
areas with sparse or
nonexistent geodetic
documentation
Centralized
-------
coordinates of the nearest street intersection (approximating the
latitude/longitude coordinates of the actual entity). The software first
identifies the street segment that includes the entity's address in its
address range. Assuming that addresses along the street are
proportionally spaced by address number, the software then
interpolates to identify a point along the street that theoretically
corresponds to the entity's address. For example, if a street file has a
segment labelled 1000 to 5000, the software will place an address of 1530
at a point 1530 - 10007(5000 - 1000) = 0.1325 times the length of the
segment from the end labeled 1000 and then calculate the latitude and
longitude coordinates of that point based on the coordinates at the
beginning of the street segment.
This method requires specialized software (a geographic information
system) and data (street segments digitized to a standard coordinate
system). Specialized GIS software is required because the addresses
must be rectified to an x/y coordinate framework. These capabilities
are offered by ARC/INFO at the ARC level. The digitized street
information, which is usually the most expensive capital component,
can be obtained from the Bureau of the Census Dual Independent Map
Encoding (DIME) files, covering urbanized areas, and the Topologically
Integrated Geographic Encoding and Referencing (TIGER) files
currently available in a pre-census format for all 50 states and outlying
areas. TIGER/Line, which is the line network of the TIGER system,
utilizes cartographic information from Geographic Base Files
(GBF)/DIME and from USGS 1:100,000 scale national map series. In
addition to the line segments, these files have census geographic codes
and address ranges for the right and left side of each segment in
metropolitan areas. These detailed files are currently available only for
350 of the largest metropolitan areas.
Additionally, private vendors provide address matching services from
proprietary street file data bases. These files are usually enhanced
versions of the DIME files, corrected for address range attributes or
street trace information. These private vendors often maintain large
numbers of existing business entity location coordinates. The private
vendors usually can provide a range of solutions for addresses falling
outside DIME coverage areas through matching facilities to ZIP code
centroid or postal routes. Accuracies vary from vendor to vendor,
however, and are not well documented.
Very little manual effort is required to perform address matching
because it normally is a computerized batch operation. Assuring
quality input information, however, could involve significant
expenditures depending upon the data base used. Direct costs
associated with address-matching consist of acquiring the address data
base and the address-matching software. For a typical highly urbanized
3/92 LDPIG 7-5,
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area of approximately 180 square miles, the data base cost ranges from
no charge for Bureau of the Census DIME files, to approximately
$10,000 for commercial conversion software. Of the two options just
presented, the commercial data would be of higher quality, because it
reflects digitization of street networks from USGS quadrangle sheets
and incorporation of DIME file information. DIME files alone do not
represent accurate topological structures. Other costs for EPA would
result from the need to use ARC/INFO, particularly the NETWORK
module. Depending upon the platform used, this software costs
anywhere from $10,000 to $80,000, plus the cost of the necessary
hardware and training. In the studies performed in support of the
LATF1, per point costs to obtain latitude/longitude coordinates through
address matching ranged from $7 to $10 with the services of a vendor
and between $20 - $30 when performed "in house."
The accuracy associated with address matching depends upon how the
proportionality of a city's addressing scheme, the particular software
used, and the quality of the initial data (address information and the
baseline street file). Another limitation of address matching is that
digitized street data are available only for approximately 350 U.S. urban
areas. Additionally, errors during address matching commonly result
from nonstandard spellings and abbreviations and from missing or
incomplete address data in facility and street files. For example, one
company's address may be recorded in a data base as 7562 East 12th
Street, S. while the same address is entered as an address matching
input as 7562 East 12th Street, South. This inconsistency may cause a
"match reject" which would then be placed in a special file for the user
to review manually and correct. Front-end data quality efforts or
sophisticated address matching software can compensate for
abbreviations and other systematic anomalies. Spelling differences and
incomplete address information are difficult to rectify, however.
Additionally, the data files are not always topologically correct. The
line work often has gaps or the address ranges are incorrect or missing.2
In studies conducted to date, accuracies of latitude/longitude
coordinates created from conversion of street addresses have ranged
from 5 to 100 meters. This variance is explained by the proportional
estimation algorithm used in address matching.
Another major limitation of address matching arises from the fact that
addresses do not accurately represent the locations of the actual pipes,
stacks, or similar entities which are of environmental concern. The
*Four sites (San Gabriel, CA, Chattanooga, TN, Nashua, NH, and Old Southington, CD with a total of 27 points were
analyzed against a control or a known location in a geocoding study performed for the LATF. In the case of the San Gabriel
Basin, GPS was the control and other methods were compared to it for accuracy.
^Even the highest quality data vendors require the user to sign an agreement acknowledging no guarantee of the integrity
of the data.
3/92 LDPIG 7-6
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suitability of using an cm-street location to approximate the location of
an off-street entity must be determined based upon Data Quality
Objectives.
ZIP Code Centroid
Location coordinates also can be assigned based on the centroid of the
ZIP code in which the entity is located. Using this approach, all entities
within a ZIP code district are assigned the same centroid coordinates.
The sizes of these districts are inversely proportional to population
density and may vary from a single building in Manhattan to over
10,000 square miles in Alaska. Due to this variation based on
population density, the most accurate ZIP code centroid locational
coordinate determination can be expected in urban areas.
Accuracy for this method can range between 50 meters to many
kilometers depending upon the size of the ZIP code district. In an EPA
test of 191 locations derived from aerial photography in the
Chattanooga area, 88% of the facilities had actual locations between one
and five kilometers from their respective ZIP code centroid. The
median distance was three kilometers. Only one facility was located
within 100 meters of the ZIP code centroid.
This method requires little manual effort because calculations can be
performed in batch mode on a computer. The cost associated with the
ZIP code centroid method is usually between $0.05 and $0.10 per point.
This method can only be performed for an entity for which a ZIP code
exists and for which DQOs clearly warrant very crude locational
accuracy.
7.2.2 Conversion from One Coordinate System to Another
Conversion between coordinate systems occurs through the use of various
algorithms that project from one coordinate system to another (e.g.,
Universal Transverse Mercator [UTM], state grid, etc. to latitude/longitude).
Two options are described for converting data between coordinate systems.
These are ARC/INFO and General Coordinate Transformation Package
(GCTP).
ARC/INFO
ARC/INFO, developed by the Environmental Systems Research
Institute (ESRI), is a GIS that can perform coordinate transformation.
This GIS, which can be accessed through a micro, mini, or mainframe
computer will inter-convert UTM and State Plane coordinates to
latitude/longitude coordinates. ARC/INFO is the EPA standard for GIS
3/92 LDPIG 7-7
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software and currently is available on the PRIME computers located in
each region.
General Coordinate Transformation Package
The United States Geological Survey (USGS) has recommended the
General Coordinate Transformation Package (GCTP) for use by Federal
agencies to convert data between geodetic coordinate systems. Use of
this PC-based package is endorsed by EPA. GCTP can be used to convert
from virtually any coordinate system, including UTM and State Plane,
into latitude/longitude. Conversion through GCTP requires very little
manual effort as it operates in batch mode. During conversion, the
accuracy associated with the original coordinates is maintained. No
new error is introduced by the conversion.
A limitation of the GCTP is that it will only do batch conversions on
PC data files. For many EPA users, this limitation may mean
transferring data from a mainframe system to a PC and back again.
7.2.3 Conversion from One Datum to Another
Two options are described for converting from NAD27 to NAD83. The
software that implements the conversion are NADCON and
CDATUM.
NADCON
The National Geodetic Survey has developed NADCON software to
transform large quantities of existing coordinate information between
NAD27 and NAD83. NADCON interpolates locational data to convert
from one datum to another. The interpolation is performed through
minimizing total curvature of shift values, where curvature is defined
as the rate at which the shifts vary fromj?lace to place. Shift
information is obtained for more than 100,000 first- and second-order
control stations. This conversion method has been programmed in
FORTRAN 77 for use on many computing platforms, including PCs.
NADCON preserves accuracy of existing coordinates to approximately
15 centimeters for the conterminous U.S. where geodetic control is
good. In remote areas, with sparse or nonexistent geodetic control,
accuracies are not as high, but are rarely worse than 1.0 meter. This
level of accuracy is adequate for cartographic products with mapping
3/92 LDPIG 7-8
-------
scales of 1:200 and smaller.3 The final accuracy of converted
coordinates is dependent on the accuracy if the input coordinates.
Data to be converted from NAD27 to NAD83 using NADCON must
first be converted to ASCII. NADCON requires very little manual
effort as the conversion can be done via batch processing. For further
information on this product, contact the Geographic Information
Systems (CIS) Program within OIRM or the National Geodetic
Information Branch in Rockville, Maryland, at £501) 443-8631.
CDATUM
The designation of ARC/INFO as the EPA standard for CIS software
has necessitated the need for software which converts locational data
between NAD27 and NAD83 in ARC/INFO format. Accordingly,
EPA's Environmental Monitoring Systems Laboratory (EMSL) - Las
Vegas developed CDATUM, which uses NADCON algorithms and
control files to perform coordinate transformation between datums on
ARC/INFO coverages. CDATUM is FORTRAN Vll-based and takes
advantage of the ARC/INFO subroutine libraries available on the
LVGIS VAX which maintains an ARC/INFO object code license.
7.2.4 Guidelines on How to Choose a Locational Data
Conversion Method
A detailed process for selection of a geocoding method is given in the Guide
to Selecting Latitude/Longitude Collection Methods accompanying this
document. Suggestions for selection of a conversion method are given here.
As discussed in the preceding text, many methods are available for converting
existing non-coordinate and coordinate data into latitude/longitude points.
In all cases, the conversion method used should be identified in the
"METHOD" data element. Detailed guidance on documentation of the
method used to convert lat/long coordinates can be found in Section 2.2.4 of
this document. When choosing a conversion method, the following factors
should be considered:
Data Quality Objectives (DQOs) - DQOs should be determined
before proceeding with the conversion method choice. The DQO
process is valuable for identifying the level of required accuracy
for a particular entity or application. Once DQOs are established,
the decision of whether to convert existing location data or
collect new data can be made in accordance with EPA's 25-meter
accuracy goal.
3/The Impact of the North American Datum of 1983 on Cartographic Products," Federal Digital Cartography Newsletter.
Summer 1990, p.6.
3/92 LDPIG 7-9
-------
Type of conversion needed Does the existing data base have
address information, UTM, or State Plane, or are latitude and
longitude coordinates available but need to be converted
between datums? The answer will determine what type of
software is needed.
Type of entity for which the information has been collected Is
the location for a facility, an outfall, a smokestack, etc.? This
answer will assist in determining the feasibility of certain
conversion methods, such as address conversion software.
Location of the entity Is it in a major metropolitan area or a
rural area? Again, this criterion will determine the applicability
and expected accuracy of certain methods, such as address
conversion software. '
Available resources What resources (personnel, time, and
funds) can be allocated to addressing LDP requirements? This
consideration will help decide whether to collect new data or to
apply a conversion method.
Hardware environment Does the organization have access to
the mainframe or only PCs? This answer will help in deciding
whether certain software will be usable by a particular
organization.
Program managers should take these factors into account when deciding
which conversion method to use for non-LDP-conforming data. In certain
cases, these factors may indicate that it would be more efficient and effective
for an office simply to collect new location data.
7.3 Collection Methods
A wide variety of methods exists for collecting new latitude/longitude coordinates.
The following section provides a brief description of many of these methods as well
as a discussion of the level of expertise required, limitations, accuracy, time, and
cost associated with each.4 Additionally, general guidance is given on how to choose
a collection method. The methods discussed in this section are summarized in
Exhibit 7-3. Cost and accuracy associated with each method are illustrated in Exhibit
7-4.
of this information was obtained from: Fitzsimmons, Charles K. "Evaluation of Selected Methods for Determine
Geographic Coordinates." and "Description of Location Data Collection Techniques", Environmental Research Center,
University of Nevada, Las Vegas.
3/92 LDPIG 7-10
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NJ
1
Exhibit 7-3
Comparison of Locational Data Collection Methods
Method/
Characteristic
Description
Entity Type
Accuracy
Cost/Point
Required
Expertise
Manual Effort
Limitations
Organizational
Considerations
Conventional
Surveying
Traditional method of
measuring horizontal
distances, elevations,
directions, and angles
for the purpose of
gathering locational data
Any entity within
terrain limitations
Very high - to the
centimeter- level
High
Requires trained,
licensed surveyor
High. Each site must
be visited to obtain
a reading.
Limited use in rough/
inaccessible terrain
Requires high level
of expertise
Incremental/
Centralized
Map Interpolation
Geopositioning by means
of maps through either
manual effort* or
digitization
Any entity which
can be located on a map
25-1000 M depending on
map scale and skill of
interpolator
$20-$60/Point
Requires basic map
knowledge
High.
Limited in accuracy
by map scale, accuracy,
orientation, and
experience of map
interpolator
Incremental/
Centralized
Photo Interpolation
Interpolation performed
either manually or through
digitization of aerial photos/
satellite images
Any entity which can be
located by remote sensing/
aerial photography
5-300M depending on
resolution and scale
$40-$60/Point
Requires trained
photointerpreter
Moderate to high.
Limited in accuracy by photo,
optical, and perspective
distortion, relief displacement,
and experience of
photointerpreter
Incremental/
Centralized
LORAN-C
Location system using
broadcasting stations
and receivers to
determine latitude/
longitude
Any entity within a
LORAN- C coverage
area
50-150M with correction
factors applied
Receiver cost of approx
$1500
$100/Point
Requires knowledge of
LORAN receiver,
publications*, and
correction methods
High. Each site must
be visited to obtain
a reading.
Limited coverage in
most inland regions
Susceptible to bad
weather/ atmospheric
disturbances
Incremental/
Centralized
GPS
System of satellites,
ground stations, and
receivers which provide
global position
infromation
Any entity within the
GPS satellite coverage
area
100-200M for autonomous
selective availability;
15-100M for differential
mode
Receiver costs range from
$30004150000
$40-$170/Point
Requires technician with
knowledge of GPS
receiver.
High. Each site must be
visited to obtain a reading.
Satellite availability
limited
Accuracy degraded
under selective availability
Incremental/
Centralized
-------
I
Exhibit 7-4
Cost vs. Accuracy Curves of Lat/Long Collection Methods
8
10 ,
01-
10
Address
>/zif
^^
00 1C
a**-
^
Matching
' Centroids
* m
Locatk
25 mat
10 1
lap Interpolation i/
^ ^-
Photo Interpretati
nal Data Policy
vgoal
0 1
GPS
>n
0.
Goal:
25 m or better
Accuracy (meters)
-------
7.3.1 Conventional Surveying
Conventional surveying is a traditional geocoding method that requires
precise measurements by a licensed surveyor. There are many types of
conventional surveys, such as cad astral surveys which are performed to
establish legal and political boundaries for land ownership and taxation
purposes, and geodetic surveys, which are global surveys performed to
establish control networks used in land mapping. Surveying can achieve
very high accuracy - to the centimeter level. If surveying is used in concert
with other more sophisticated techniques, such as photogrammetry, very
high accuracies can be virtually assured. There are some limitations to
surveying, however. Tor example, surveying cannot be performed easily in
very rough terrain and is, therefore, most appropriate for accessible areas.
This method also necessitates a trained, sometimes licensed person to
perform the survey. Additionally, due to the labor intensive nature of
surveying, costs per point tend to be quite high?
7.3.2 Map Interpolation
Map interpolation is a method of geocoding measuring relative distances
using maps, usually USGS topographic quadrangle sheets. Coordinates of a
point on a map are determined either through manual or automatic
interpolation. Topographic maps are printed with 16 map tics per quadrangle:
four corner tics and 12 ulterior tics. On a 7.5 minute map, tics are placed every
2.5 minutes. To determine coordinates for points of interest manually, a scale
(such as a bar scale, an engineer's scale, or a graduated ruler) that matches
some increment of latitude and longitude on the map is used to measure the
x and y distances from the relevant point to the nearest map tic. The scale
values are then multiplied by the appropriate factors to obtain the degrees,
minutes, and seconds for latitude and longitude and are added to the
coordinates of the map tic.
Coordinates also may be obtained automatically through digitization.
Digitization involves the transformation of pap^r maps into a computer-
readable format through marking or plotting on a map and then using a
digitizing table to input relative positions of points, lines, or polygons with
unknown coordinates. The digitization software extrapolates the location of
the points marked on the map by comparing it to the known coordinates of
the map corners and calculating the distance and direction of the point from
the corners. The coordinates of each point are then stored in the computer.
The accuracy associated with map interpolation can be no greater than that
associated with the map itself and is usually less due to the potential error
introduced by the interpolation process. National Map Accuracy Standards
American Management Systems, Inc., "Geopositioning: Techniques, Technology, & Services (Draft)" October 24,1988, p.4.
3/92 LDPIG 7-13
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maintained by USGS specify a maximum horizontal deviation from the true
location of not greater than 0.02 inches on a map. The relative accuracies of
7.5 minute quadrangle maps, therefore, are as follows:
A 1:24,000 scale map - 40 feet.
A 1:63,000 scale map - 105 feet.
A 1:100,000 scale map - 167 feet.
A 1:250,000 scale map - 417 feet.
For the highest accuracy, maps made from stable materials, such as Mylar,
should be used instead of paper, as this removes potential changes in map
dimensions due to humidity and temperature. The largest source of error in
map interpolation occurs in the field, when difficulties can be encountered
while orienting the map to observed entities and then visually interpolating
the position on the map. If the interpolation is not performed in the field
(office-based), the point or facility must be located on the map using an
address, aerial photograph, or other source of information. In the Guide to
Selecting Latitude/Longitude Collection Methods, the achievable accuracy for
map interpolation using USGS l:24000-scale maps ranges from 12-50 meters
for easily identifiable features. Larger scale (i.e., higher resolution) maps will
yield accuracies in the 5-25 meter range.
Map interpolation can be utilized for any entity that can be clearly located on a
map. The USGS 1:24,000 scale, however, is usually the smallest reasonable
scale for locating sub-facility points, such as stacks and pipes. One potential
drawback associated with this method is the inability of the user to locate a
site accurately due to the scale or date of map being utilized. For example, an
old or outdated map may not depict the entity or show other easily
recognizable features.
According to the Guide to Selecting Latitude/Longitude Collection Methods,
costs for office-based map interpolation ranged from $40 to $60 per point6
while field-based efforts range from $28 to $40 per point. The major
component of this cost is labor and varies depending upon the interpolator's
familiarity with map products and scales. In general, map interpolation
requires a moderate to high level of manual effort. Although a trained
specialist is not required to locate items on a map, the interpolation of points
from USGS topographic maps requires at least a basic knowledge of map
concepts, including symbology and measurement. Another consideration of
map interpolation cost is the expense of buying the maps themselves. Paper
maps from USGS usually cost less than $5.00 each while Mylar maps cost
$56.00 each.
°This cost figure includes an estimate for research time.
3/92 LDPIG 7-14
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7.3.3 Photo Interpretation
Photo interpretation may be performed either on aerial photographs or
satellite images in a manner similar to that used with maps. Entities are
identified on the photographs or images, the geographic positions are rectified
to a map, and coordinates are either manually or digitally interpolated using
one of several techniques. One technique involves locating an entity through
the use of ground-based reference points, such as roads and streams.
Additionally, a zoom transfer scope (ZTS), which optically superimposes a
view of the photograph on a map, can be used to interpolate. It is important
to note that photo interpretation must be used in conjunction with a map or
some other device that enables the user to rectify points on the photo to
coordinate planes.
The main advantage of photography and imagery over maps is that they are
usually more current than maps. Aerial photographs and images can usually
be acquired within 24 hours, limited by weather conditions and the source
utilized. Maps usually are several years old at best.
Color infrared film at 1:24,000 scale is preferred for aerial photography. The
National High Altitude Photography Program maintains an extensive U.S.
coverage at approximately 1:80,000 scale, and new photographs at a 1:40,000
scale are becoming available. The process through which satellite images are
obtained is referred to as remote sensing. Satellite imaging technology
records the reflection of both visible and invisible light from the earth's
surface and then converts these values to computer-readable format.
In spite of the apparent "realism" in photogrammetry, this method also has
its limitations. Photographs vary in vertical scale across their extent whereas
maps do not. They exhibit "relief displacement" in which closer features
have larger images than farther features. The tilt angle and focal length of the
camera also introduces a "perspective distortion." Such distortions increase
from zero at the center of the image to a maximum at the edges of the image.
Special equipment, such as an analytical stereo plotter, is used to produce
maps from aerial photographs. This equipment removes the relief and tilt
distortion from the source photographs.
In addition, there are no grids or tics on the photos by which to reference the
coordinates of a plane. Therefore, coordinates must be calculated from photos
with additional information including known reference points, current
maps, addresses, elevations of the points in question, elevations of the
camera, and the focal length of the camera. Points of interest on the photos
can also be digitized as in map interpolation.
The accuracy achieved from photo interpretation is dependent upon the
resolution and scale of the photograph as well as the techniques used to
remove relief displacement and perspective distortion. This method can be
3/92 LDPIG 7-15
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extremely accurate with an average accuracy under 5 meters for most
common photo scales. To further improve the accuracy associated with
photo interpolation, aerial photography can be merged with GPS as a "hybrid
system/' Hybrid systems are discussed in more detail in Section 7.3.6 of this
document.
Photo interpretation requires a moderate to high amount of manual effort.
For example, EPIC7 has outlined the planning steps for an analysis of aerial
photography. These steps are geared toward hazardous waste sites and may be
more detailed than necessary for other programs. The following basic steps
would be required for most locational data collection projects using
photographs or remote satellite images:
Obtain appropriate maps
Prepare flight plan
Search for archive photos and order the relevant photos
Contract flights
Check photos for quality
Search for points or areas of interest
Use maps and address information to identify entities
Prepare data for transfer to other data systems as required.
Photo interpretation can be used for any entity that can be located on an aerial
photograph for a cost of between $40 and $100 per point. Aerial photographs,
not being labeled and not using the easily recognized symbology of maps,
require a trained photointerpreter to perform the interpolation, adding a
significant cost to this method. In addition, photo interpretation can be used
only for entities that can be located on aerial photographs.
7.3.4 LORAN-C
LORAN-C (Long Range Navigation) is a location system which is usually
used to aid ships and planes in navigating. LORAN employs broadcasting
stations and portable receivers to determine latitude and longitude. These
broadcasting stations are arranged in triads where one is the "master station"
and the other two are "slaves." Each station broadcasts signals at specified
time intervals. Coordinates are then determined by calculating the difference
in the amount of time required for a signal to reach a receiver from the
master and slave stations. This calculation allows a distance hyperbola to be
determined, thus giving the distance of the receiver from the slave station.
Calculating the distance hyperbolas for both slave stations provides the
relative location of the receivers through triangulation. Because the LORAN
master station's absolute location is known, the receiver's absolute location
can be computed. LORAN coverage is available with at least limited
7See Appendix B - Contacts for LDP Implementation Assistance
3/92 LDPIG 7-16
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reception for most of the northern hemisphere. Locations may be calculated
at distances up to 1500 km over land and up to 300 km over water.
According to the Federal Radionavigation Plan, accuracy for a LORAN at sea
is 436 meters with a repeatable accuracy of between 19 and 90 meters. In U.S.
Coast Guard studies, 150 meter accuracies have been observed 600 km from
the master station. EPA Region IV and EMSL-LV tested LORAN in December
of 1987 in the Chattanooga study. The researchers found an unconnected
accuracy of over 600 meters from the true locations. When correction factors
(calculated from 59 absolute locations) were applied, accuracy improved to
between 5 and 153 meters from the true locations. A discussion of LORAN-C
was not included in the Guide to Selecting Latitude/Longitude Collection
Methods.
LORAN can be used to obtain coordinates for any location within a coverage
area and by any individual with a LORAN receiver. However, LORAN is
most effective in coastal regions and at sea, and is relatively ineffective in
inland regions. LORAN was designed for maritime usage, therefore most
LORAN transmitters are located in coastal regions. Also LORAN frequencies
are assigned to take full advantage of propagation over water. LORAN
performs best on clear and dry days and worst on cloudy and wet days. In fact,
the major source of error in LORAN measurement is caused by atmospheric
disturbances, such as electrical discharges, or by power-generating equipment.
These disturbances, which are most likely in urban areas, warp distance
hyperbolas and cause incorrect calculations in the receivers' relative locations.
These errors occur up to an order of +927 meters (0.5 minutes) and remain
relatively constant over several hours. To greatly reduce error, correction
factors can be calculated from measurements obtained at sites where the
absolute location is known. Errors in LORAN measurement can also be
introduced by weak signals and by the relative position of the receiver to the
LORAN stations. If a receiver is close to high elevations or other landforms
which block signals, accuracy will decrease.
Coordinates can be obtained for approximately $100 per point with labor being
the greatest component of this cost. Manual effort required for LORAN is
very high as a technician must participate in survey planning activities,
survey area reconnaissance, individual site visits and measurements, and
post-processing. In Chattanooga, 70 locations were surveyed in 220 hours
with an average rate of three hours per point (including the time required to
calibrate the receiver and to perform repeated measurements at one point).
Another component of cost is the expense of a LORAN receiver. A single
LORAN receiver typically costs around $1000.
3/92 LDPIG 7-17
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7.3.5 Global Positioning Systems (GPS)
A detailed primer on GPS accompanies this document. A brief introduction
to GPS is given here.
The NAVSTAR GPS (Navigation System with Timing and Ranging Global
Positioning System), a system of satellites, ground stations, and receivers, was
designed to provide 24 hour global, three-dimensional position information
in real-time to the Department of Defense (expected to be fully deployed in
June 1992). When fully operational it will be possible to obtain nearly
instantaneous positions of aircraft, land vehicles, and ships 24 hours a day,
any place in the world, from a constellation of satellites using GPS
technology. This method, which avoids many of the problems inherent to
land-based methods will also support civilian applications with a slightly
lower accuracy.
Portable GPS receivers compare coded time and position data broadcasts from
the satellites to calculate locations. Each of the satellites in the network
broadcasts two types of radio signals, C/A-code and P-code, on preassigned
frequencies. Signals must be received from at least four satellites
simultaneously to unambiguously calculate location in three dimensions
(latitude, longitude, and elevation). If the elevation of a point is already
known, then only three satellites are needed. Currently, 19 out of the
planned 27 satellites are operational. This limited deployment restricts the
acquisition of satellite signals and affects the accuracy and availability of GPS
data. Studies have shown that there is a high degree of variance introduced if
a receiver shifts its "lock on" from one set of satellites to another. Therefore,
due to the limited satellite availability, significant time must be spent
planning field work around satellite visibility. This problem will diminish in
1992, with scheduled deployment of the full constellation of satellites.
Two types of GPS receivers exist: navigation units (C/A code receivers) and
the more precise geodetic units (P-code receivers). Geodetic receivers are
more precise because they receive a much more complex signal and are
capable of assessing signals from more than four satellites at a time
(centimeter accuracies are expected with this type of receiver when the system
is fully deployed).
GPS can be used to locate positions on the surface of the earth in two modes:
autonomous or differential/relative. Autonomous positioning utilizes only
3/92 LDPIG 7-18
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one receiver at the point of interest and depends upon the ephemeris8
broadcast by satellites. Higher accuracy is possible through the use of the
differential mode, where two or more receivers are used simultaneously -
one at a point of known coordinates and the other at the point of interest.
The receiver at the known benchmark corrects errors in the satellite's
transmitted signal, including those purposely introduced by the military to
degrade the effectiveness of GPS technology in the civilian community. The
coordinates of the point of interest are determined through simultaneously
post-processing the receivers' measurements by computer. The accuracy is
then a function of the baseline distance between the two receivers and ranges
between two and five million parts per million of the baseline. For example,
if the two receivers are 160 kilometers apart, the expected deviations in
accuracy are less than 11 meters. Tests have found that centimeter level
accuracy is possible through the use of two receivers taking 45 to 60 minute
static measurements. Millimeter accuracy is achievable if post-processing
utilizes ephemeris data from the National Geodetic Survey (these data are
available approximately two weeks after a GPS reading is obtained).
The military reserves the right to selectively degrade or even to deactivate the
NAVSTAR system to protect national security interests. Degradation, which
is referred to as "selective availability," implies that the satellite signals are
programmed to provide erroneous locations to Earth receivers. The
Department of Defense guarantees, however, that 100 meter accuracies will
still be achievable under selective availability. This condition may be
overcome by the use of differential correction and post-processing software.
The accuracy associated with GPS is quite high, usually within +/- 25 meters.
Under optimal conditions and with the use of a geodetic-quality GPS
instrument, accuracies can be obtained to better than a centimeter. The
accuracy depends upon the type of GPS receiver being used. For example, a
high-end geodetic quality instrument (P-code receiver) can achieve extremely
high levels of accuracy while a lower end navigation quality instrument
achieves lower levels of accuracy. Accuracy can be improved for civilian
receivers by performing static observations. When all satellites are deployed
in mid-1992, GPS (in differential mode) should regularly be able to achieve
better than 10 meter accuracies.
Although accuracy is not affected by radio frequency interference or weather, a
clear line of site (LOS) from the receiver to the satellite must be maintained
(i.e., satellite must be a minimum of 20 degrees above the horizon). Another
limitation of GPS devices currently is the limited satellite availability or
"window" due to the incomplete GPS constellation.
o
Ephemeris is the prediction of current satellite position, given in a table or transmitted to the user in a data message.
3/92 LDPIG 7-19
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The average collection cost per point, as estimated in the Guide to Selecting
Latitude!Longitude Collection Methods, was between $50 and $100 for
centrally planned, dedicated GPS surveys. For decentralized GPS surveys (i.e.,
performed by field staff already on-site conducting other duties) the cost per
point was between $35 and $70. These cost figure include a large amount of
labor because a high degree of manual effort is needed for GPS. A technician
must be sent to each site.
It must be emphasized that, in its present state, GPS is not a "push button"
operation. Technicians must be adequately trained in pre-survey, survey, and
post-survey procedures. The technician in the field must be constantly aware
of signal strengths, satellite availability, noise sources, and topography.
When a survey is completed, a tremendous amount of data must be sorted
and screened before an optimal location solution is determined.
Additionally, GPS is quite expensive with C/A-code navigation receivers
ranging from $3000 to $15,000, and P-code geodetic quality receivers starting at
$30,000.
7.3.6 Hybrid Systems
Hybrid systems are defined in this context as the use of a combination of
technologies. LORAN, GPS, and/or inertial technologies have been
incorporated into several devices that seek to capitalize on the strengths of
each system. An example of a hybrid system (i.e., map interpolation/photo
interpretation) is discussed in Section 7.3.3 of this document.
Some hybrid systems offer the advantage of using the GPS signal during
satellite availability and of using a back-up technology when the window
closes. These hybrid systems are subject to the same types of errors as LORAN
and GPS. Additionally a significant post-processing problem occurs if both
technologies were used for a single mapping session. Error sources are
different for each technology and result in significant differences in locational
accuracy which must be resolved. There is little data available on these
systems, but accuracies and variable costs are thought to be similar to those
experienced with GPS and LORAN. Additional costs will be incurred if
significant post processing is required due to a shift in technologies during a
mapping session. Costs for hybrid units range from $3,000 to $10,000.
7.3.7 Guidelines on How to Choose a Locational Data Collection
Method
As discussed in Chapter 3, GPS is the preferred technology for acquiring
location identification data. Guidance for employing GPS is given in the GPS
Primer accompanying this document. Technical assistance for GPS can be
found within the EPA Regional GIS/GPS Work Groups.
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GPS may not be suitable for all circumstances. A process for determining the
most suitable locational data collection method is given in the accompanying
Guide to Selecting Latitude/Longitude Collection Methods. Another method
may be found to be more affordable, or the circumstances may warrant less
stringent accuracy requirements. In all cases, the collection method used
should be identified in the "METHOD" data element. Detailed guidance on
documentation of the method used to collect lat/long coordinates can be
found in Section 2.2.4 of this document. If a method other than GPS is
deemed necessary and supported by clearly defined DQOs, the following
factors should be taken into consideration:
Type of entity for which the information is being collected Is
the entity in question a facility, an outfall, a smokestack, etc.?
This information will help managers decide which type of
method can be used. For example, only certain scales of maps
can be used for locating sub-facility points (e.g., stacks or pipes).
Photo interpolation can be used only for entities that can be
located on aerial photographs (e.g., not under ground or under
tree-cover).
Location of the entity Is the entity located in a major
metropolitan area, in a coastal region, or surrounded by rough
terrain? This consideration will help determine which method
is most appropriate. For example, LORAN is effective in coastal
regions. Surveying cannot easily be performed in rough terrain.
Program requirements for accuracy What level of accuracy is
the program attempting to achieve? The level of accuracy
required in a program may dictate use of a certain type of
method, especially if the accuracy requirements are stringent.
EPA's locational policy goal is to attain better than 25 meter
accuracy for all locational data by 1995. The point of reference for
accuracy should be the most visible and accessible point of the
entity for which lat/long is being treasured. This point should
be documented in the "Description" data field.
Available resources What resources (personnel, time, and
funds) can be allocated to the collection? Resource availability
may determine selection of certain methods. GPS requires a
high degree of manual effort and also is quite expensive. It may
not be a viable option where resources are limited.
Necessary expertise Does the program have individuals who
possess spatial data collection expertise, will they have to train
existing personnel, or will they rely on contractor expertise?
Decisions relating to personnel expertise and training affect
overall costs and, therefore, desirability of certain methods.
3/92 LDPIG 7-21
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Provider of the information Who provides the information
(i.e., the facility operator, EPA staff, etc.)? The response to this
question has implications for the type of method used because
certain types of equipment may not be accessible to all parties
and novice data providers may require EPA to draft extensive,
clear instructions on use of the method.
Through responding to these questions, referring back to the text and the
summary tables in this document, and consulting EPA technicians in the GIS
Program, at EMSL-LV, and at EPIC, project managers should be able to
determine which of these collection methods best suits their needs and Data
Quality Objectives. A process to follow for choosing a location identification
method is provided in the Guide to Selecting Latitude/Longitude Collection
Methods accompanying this document.
3/92 LDPIG 7-22
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Chapter 8
SYSTEM IMPLICATIONS
-------
8. SYSTEM IMPLICATIONS
The Locational Data Policy sets forth requirements for collecting and documenting
lat/long coordinates for entities regulated and/or tracked under Federal
environmental law. The policy does not specifically address the automation of
locational data after they have been collected and documented. Because the entities,
processes, and systems vary so greatly among environmental programs it is difficult
to generalize how data should be computerized. Some guidelines, however, are
provided for managing locational data in computer systems. These guidelines
promote uniformity of locational data and expedite their access by primary and
secondary users. Therefore, the formats for locational data are suggested in this
chapter, and are recommended for both computer (and paper) records.1
8.1 Locational Data Management
There are many issues relating to data automation that should be addressed even
before lat/longs are collected and documented. With the ultimate objective being
high quality, accessible locational data, uniformity in the management of
computerized resources is necessary.
8.1.1 Relationship Between LDP Data Elements
.
The Locational Data Policy requires that four elements be collected: latitude
and longitude, method, accuracy, and description. Definition for these
elements are as follows:
"Lat/long coordinates" are a repeating set of numeric fields to
allow a point, line, or area to be defined.
"Method" is a set of coded alphanumeric fields with three
components (see Chapter 2) and is a descriptor of the technology
used to collect lat/long coordinates, the datum, and the map
scale.
"Accuracy" is a free-format, numeric field with prescribed
components that describe the accuracy rnnge of the locational
data (Chapter 2); the accuracy field may be linked in a computer
system to the method field so that accuracy values (ranges) can
be derived based upon the type of method used.
"Description" is a free-format, textual field containing certain
types of information describing the exact place where lat/long
was determined and whether a point, line, or area is being
defined.
^Names for LDP data elements are specified in Section 5(d) of the LDP.
3/92 LDPIG 8-1
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8.1.2 Structure and Format of LDP Data Elements
The following recommendations promote consistency in the structure and
format of the Agency's locational data.
Latitude and Longitude
Lat/Long data elements are used to describe the geographic location of
the point being measured. The following statements apply to these
fields:
Latitude and Longitude are to be two separate data
elements
Latitude is to be presented, in all system outputs, before
longitude
There are to be no embedded blanks between values of
degrees, minutes, seconds, and/or fractions of seconds
(e.g., +DDMMSS.SSSS)
Each measurement (i.e., latitude AND longitude) should
have a symbolic hemisphere qualifier preceding it ("+" or
"-"); those values MUST NOT be letters (N, S, E, or W); if
no qualifier precedes a coordinate, that coordinate should
be assumed to be a positive number (in accordance with
common mathematical convention)
Values for degrees, minutes, and seconds that are less-
than-ten should be padded with leading zeros; thus a
value of six minutes should be given as "06." Values for
degrees longitude that are less than one hundred should
similarly be preceded by zeros. Ninety-seven degrees, 11
minutes, and 6 seconds west longitude should be encoded
as-0971106.
The decimal point need not be stored as a character if the
system internally justifies the coordinate values
appropriately; the decimal point must appear, however, in
all outputs.
Method
Method is a set of three fields describing how the lat/long coordinates
were determined. Exhibit 2-2 summarizes the codes that should be
used to document method.
3/92 LDPIG 8-2
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The method data element should allow up to 10
alphanumeric characters representing the specific code for
method and/or tool used (Exhibit 2-2).
The data element for datum should be structured as two
numeric digits to communicate the year of the datum
used (e.g., 83).
The data element for scale should be the "x" value of the
lx representation of the scale (e.g., "100,000" for a 1:100,000
scale map).
The method fields are left-justified (one reads from the
left) and should have no embedded blanks to separate
components.
Agency-wide standardization of method codes is imperative because
this field will often be used to select locational data for secondary use.
EPA GIS program managers will maintain the complete list of codes to
be used to document method.
Accuracy
The accuracy data element is a numeric value that conveys the range
within which the true location is expected to fall with 95% confidence.
It is expressed in the next lower unit of measurement than that in
which the coordinates are given (e.g., if the coordinates are to the
second, the accuracy should be in tenths-of-a-second). Accuracy
determined in meters must be converted to degrees of
latitude/longitude. The accuracy estimate will help secondary users
determine whether certain locational data can meet their needs.
The components of the accuracy data element are:
Numerical value of the range
Units, documented as:
deg for degrees
min for minutes
sec for seconds.
When values of accuracy are displayed, they should be preceded by a
"+/-" to indicate a range. The accuracy field should have no embedded
blanks. Examples of accuracy may be "+/- 1 sec" for a coordinate set of
"+292210,-1090720" or "+/-0.05 sec" for a coordinate set of "+292210.1,-
1090720.6." In cases where the accuracy of the latitude is known to
differ from the accuracy of the longitude, a single accuracy estimate
3/92 LDPIG 8-3
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should be provided (the least accurate of the two2). For example, if the
accuracy of the latitude value is +/- 0.5 second but the accuracy of the
longitude value is +/- 1 second, the accuracy for the whole set of
coordinates is "+/-1 sec," the least stringent of the two accuracy values.
Description
The description data element is a free-format, textual (alphanumeric)
field of unspecified length that should communicate clearly two pieces
of information:
Exactly what the lat/long coordinates are g/z NOT what
they represent (e.g., the coordinates may be of the front
door of a facility but are being used to represent the
location of the whole facility)
Whether the coordinates define a point, line, or area; that
is to say, whether there is one or more-than-one pair of
coordinates in the locational definition. This clarification
allows the data reviewer to know that there may be
several sets of coordinates defining an area, and not just
one set.
Description need not be longer than a phrase. For example, a
description might read as "discharge point at end of pipe #1" or "1st of
7 coordinate pairs starting at the northwest corner defining site
boundary."
8.1.3 Position and Function of Location Identification Data
Locational data must adequately serve two functions within a data base: (1)
they must define clearly the location of the entity they represent, and (2) they
must allow data users to select among them to secure only data of suitable
quality for their use. The position and function of the locational data in the
computer system must support these two needs.
Position of Location Identification Data
Location identification data must be clearly associated with the entity
they represent. For data bases about places, the locational data should
be a direct attribute of the entity that they represent. This association
might be accomplished by storing location identification data in the
header record or in the "CO" level, or wherever they will be clearly
linked to the entity whose location they define.
^In all cases, the goal for accuracy should be better than 25 meters.
3/92 LDPIG 8-4
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In some situations, it might be appropriate to store multiple sets of
location identification data if several tiers of entities are tracked in the
same data base. For example, if a data base identifies smokestacks at a
facility, the facility header-record should contain the location
information of the facility-in-general, but the sub-records in the data
base about each stack should contain locational data for each stack.
Another possibility is that the locational data might be associated with
a sub-unit of a complex entity and not with the entity-in-general at all,
especially if the sub-unit is the critical unit for the program.
Function of Location Identification Data
Users must be able to use location identification data in several ways:
To search through and select entities in the data base based
upon their location
To screen out unwanted entity records based on the
characteristics of imbedded metadata (e.g., too inaccurate
or unknown method).
System managers may want to review the current functional
capabilities offered to users of locational data in their system. If at all
possible, they should enhance their systems to offer selection and
screening capabilities. Merely incorporating storage of new locational
data elements is not enough to promote secondary use of the data.
Reports and queries must be modified because these enhanced system
capabilities will allow users to reap the benefits of the effort invested in
locational data collection.
8.1.4 Relationship to Other Locational Data
There are many other spatial and locational identifiers used in
environmental protection, such as address, county, hydrologic unit, and UTM
coordinates. The Locational Data Policy does not preclude these alternative
location definitions. Rather, the information required by the LDP is in
addition to, NOT instead of, other locational data normally collected. Other
types of location identification data may be useful as a double-check. For
example, lat/long coordinates can be screened for validity by comparing
against county boundary when "county" location is identified for an entity.
8.1.5 Edit Checks
Installation of edit checks into system data entry screens or software will help
ensure that locational data are realistic and complete. Edit checks can be
useful in double-checking data accuracy, and in verifying the format and
quality of data submitted by the regulated community.
3/92 LDPIG 8-5
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Various types of edit checks already are available in many EPA systems. For
example, STORET compares lat/long coordinates to county boundaries and
flags improbable coordinates. Other systems compare lat/long coordinates to
distance from the ZIP code centroid. Some systems do not allow addition of a
record to the data base if lat/long coordinates are missing. System managers
may want to devise one or more edit checks on their system depending on
their data update process and the types of other location identification data
available for each entity.
8.2 Locational Data Sharing
To promote secondary use of data and reduce costs for new data collection, OIRM
currently is examining options for sharing locational data in computerized systems.
Although some of the options are still in the conceptual phase, a brief introduction
is given below.
8.2.1 State Entry in FINDS
FINDS is EPA's inventory of facilities regulated under Federal
environmental law. On a pilot basis, EPA is allowing states to enter data
directly into FINDS. Some states are entering information into FINDS
records for facilities that are regulated only by the states.
FINDS contains basic identification data about regulated facilities and pointers
to other sources of more detailed program data. Information in FINDS
includes EPA facility ID code, name, address, and locational data. At present,
FINDS has only one set of lat/long coordinates per facility in its master record
file, but additional lat/longs (copied from National Program Systems) can be
stored in its alias file.
8.2.2 GRIDS
The Geographic Resources Information and Data System (GRIDS) is designed
to help users share baseline spatial data and to provide access to ARC Macro
Language (AML) for use in ARC/INFO Geographic Information System
applications. The main goal of GRIDS is to reduce costs associated with
development of GIS applications within EPA by providing access to
commonly needed spatial data sources and tools. GRIDS will provide the
following data sources:
USGS Hydrography Digital Line Graphs - 1:100K.
USGS Transportation Digital Line Graphs - 1:100K and 1:2M.
USGS Geographic Names Information System (GNIS) data.
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Defense Mapping Agency Digital Elevation Model (30 second
data).
USGS Land Use and Land Cover Data.
USGS Hydrologic Basin Boundaries.
USGS Federal Land Boundaries.
US Bureau of the Census Pre-Census TIGER Line Files.
US Bureau of the Census Master Area Reference File (MARF) 2.
US Bureau of the Census Summary Tape Files (STF).
US Fish and Wildlife Resources Area Geographic Database.
US EPA Reach File, Version 3.
US EPA Ecoregion Boundaries.
The AML Library module allows users to extract AML routines created and
used by other EPA program offices. GRIDS is available in prototype on EPA's
IBM 3090 mainframe in the line mode (TTY). For further information,
contact Bob Pease at 703-557-3018.
8.2.3 National Spatial Data Transfer Standard
The Spatial Data Transfer Standard (SDTS), developed by the USGS National
Mapping Division, provides specifications for the organization and structure
of digital spatial data transfer, definition of spatial features and attributes, and
data transfer encoding. The purpose of developing the standard is to promote
and facilitate transfer of digital spatial data between dissimilar computer
systems. Section 4.1.3.5 of the SDTS provides the specifications for
latitude/longitude coordinates.
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>>:*;->;-X-K'>>»W>>»>»»«*>XW:^^:->;^^^
Appendix A
LDP AND LATF RECOMMENDATIONS
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-------
'i
| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
APR 8 199?
orrici or
THE AOMINISTR ATO>
MEMORANDUM
SUBJECT: Agency Locational Data Policy
FROM: F. Henry Habicht HlVL/'
Deputy Administratc/ilN;
TO: Assistant Administrators
Regional Administrators
Associate Administrators
Inspector General
General Counsel
Through an extensive consensus-building process involving ail
Agency offices and Regions, and many of our State and federal
partners, the Agency has developed a Locational Data Policy. Tr.e
policy is designed, both literally and figuratively, to put E?A dai^
en the map.
The policy requires consistent use of latitude/longitude
coordinates throughout the Agency to identify the location of
entities that concern us. It also sets a goal, which is now
technically achievable, that all such coordinates be accurate to
within 25 meters.
I believe that your compliance with this policy, and with the
Facility ID Data Standard, will do more to enable data integration.
than almost any other initiative undertaken during my tenure at the
Agency. I urge you to read the attached policy and implementation
guidance and ensure that your organization aggressively implements
the policy.
You may direct questions on this policy and guidance to Al
Pesachowitz, Director of the Office of Information Resources
Management, at FTS-382-4465. j_^ , .^-x- j
cc: Senior IRM Officials "
National Program System Managers
Attachments
1) Locational Data Policy
2) Locational Data Policy Implementation Guidance (draft)
-------
CHAPTER I 3 - LOCATTONAt DA~A
1. PURPOSE. This policy establishes che principles for
collecting and documenting latitude/longitude
coordinates for facilities, sites and monitoring and
observation points regulated or tracked.under Federal
environmental programs within the jurisdiction of the
Environmental Protection Agency (EPA). The'intent of
this policy is to extend environmental analyses and
allow data to be integrated based upon location, thereby
promoting the enhanced use of EPA's extensive data
resources for cross-media environmental analyses and
management decisions. This policy underscores EPA's
commitment to establishing the data infrastructure
necessary to enable data sharing and secondary data use.
2. SCOP? AND APPLICABILITY. This policy applies to all
Environmental Protection Agency (EPA) organizations and
personnel of agents (including contractors and grantees)
of EPA who design, develop, compile, operate or maintain
EPA information collections developed for environmental
program support. Certain requirements of this policy
apply to existing as well as new data collections.
3. BACKGROUND.
a. Fulfillment of EPA's mission to protect and improve
the environment depends upon improvements in cross-
programmatic, multi-media data analyses. A need
for available and reliable location identification
information is a commonality which all regulatory
tracking programs share.
b. Standard location identification data will provide
a return yet unrealized on EPA's sizable investment
in-environmental data collection by improving the
utility of these data for a variety of value-added
secondary applications often unanticipated by the
original data collectors.
c. EPA is committed to implementing its locational
policy in accordance with the requirements
specified by the Federal Interagency Coordinating
Committee for Digital Cartography (FICCDC). The
FICCDC has identified the collection of
latitude/longitude as the most preferred coordinate
system for identifying location. Latitude and
longitude are coordinate representations that show
locations on the surface of the earth using the
earth's equator and the prime meridian (Greenwich,
IRM POLICY MANUAL
2100
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England) as the respective latitude and longit-de
origins.
d. The State/EPA Data Management Program is a
successful multi-year initiative linking State
environmental regulatory agencies and EPA in
cooperative action. The Program's goals include
improvements in data quality and data integration
based on location identification.
e. Readily available, reliable and consistent location
identification data are critical to support the
Agencywide development of environmental risk
management strategies, methodologies and
assessments.
f. OIRM is committed to working with EPA Programs,
Regions and Laboratories to apply spatially related
tools (e.g., geographic information systems (CIS),
remote sensing, automated mapping) and to ensure
these tools are supported by adequate and accurate
location identification data. Effective use of
spatial tools depends on the appropriate collection
and use of location identifiers, and on the
accompanying data and attributes to be analyzed.
g. OIRM's commitment to effective use of spatial data
is also reflected in the Agency's comprehensive CIS
Program and OIRM's coordination of the Agency's
National Mapping Requirement Program (NMRP) to
identify and provide for EPA's current and future
spatial data requirements.
4. AUTHORITIES.
a. 15 CFR, Part 6 Subtitle A, Standardization of Data
Elements and Representations
b. Geological Survey Circular 878-B, A U.S. Geological
Survey Data Standard, Specifications for
Representation of Geographic Point Locations for
Information Interchange
c. Federal Interagency Coordinating Committee on
Digital Cartography (FICCDC)/U.S. Office of
Management and Budget, Digital Cartographic Data
Standards: An Interim Proposed Standard
d. EPA Regulations 40 CFR 30.503 and 40 CFR 31.45,
Quality Assurance Practices under EPA's General
Grant Regulations
IRM POLICY MANUAL 2100
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5. POLTCY.
a. It is EPA policy that latitude/longitude
("lac/long") coordinates be collected and
documented with environmental and related data.
This is in addition to, and not precluding, other
critical location identification data that may be
needed to satisfy individual program or project
needs, such as depth, street address, elevation or
altitude.
b. This policy serves as a framework for collecting ar.d
documenting location identification data. It
includes a goal that a 25 meter level of accuracy be
achieved; managers of individual data collection
efforts determine the exact levels of precision and
accuracy necessary to support their mission within
the context of this goal. The use of global
positioning systems (GPS) is recommended to obtain
lat/longs of the highest possible accuracy.
c. To implement this policy, program data managers
must collect and document the following
information:
(1) Latitude/longitude'-coordinates in accordance
with Federal Interagency Coordinating
Committee for Digital Cartography (FICCDC)
recommendations. The coordinates may be
present singly or multiple times, to define a
point, line, or area, according to the most
appropriate data type for the entity being
represented.
The format for representing this information
is:
+/-DD MM SS.SSSS (l»titud«)
+/-DDD MM SS.SSSS (longitude)
where:
Latitude is always presented before
longitude
00 represents degrees of latitude;
a two-digit decimal number ranging
from 00 through 90
IRM POLICY MANUAL 2100
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DDD represents degrees of
longitude; a three-digit decimal
number ranging from 000 through 15
MM represents minutes of latitude
or longitude; a two-digit decimal
number ranging from 00 through 60
. SS.SSSS represents seconds of
latitude or longitude, with a format
allowing possible precision to the
ten-thousandths of seconds
+ specifies latitudes north of the
equator and longitudes east of the
prime meridian
- specifies latitudes south of the
equator and longitudes west of the
prime meridian
(2) Specific method used to determine the lat/long
coordinates (e.g., remote sensing techniques,
map interpolation, cadastral survey)
(3) Textual description of the entity to which the
latitude/longitude coordinates refer (e.g.,
north-east corner of site, entrance to
facility, point of discharge, drainage ditch)
(4) Estimate of accuracy in terms of the_ most
precise units of measurement used (e'.g., if
the coordinates are given to tenths-of-seconds
precision, the accuracy estimate should be
expressed in terms of the range of tenths-of-
seconds within which the true value should
fall, such as "+/- 0.5 seconds")
d. Recommended labelling of the above information is
as follows:
"Latitude"
"Longitude"
"Method"
"Description"
"Accuracy."
e. This policy does not preclude or rescind more
stringent regional or program-specific policy and
guidance. Such guidance may require, for example,
additional elevation measurements to fully
IRM POLICY MANUAL 2100
-------
characterize the location of environmental
observations.
f. Formats, standards, coding conventions or othe-
specifications for the method, description and
accuracy information are forthcoming.
6. RESPQNSISTLTTTPq '
a. The Office of Information Resources Managemer.~
(OIRM) shall:
(1) Be responsible for implementing and supporting
this policy
(2) Provide guidance and technical assistance
where feasible and appropriate in implementing
and improving the requirements of this policy
b. Assistant Administrators, Associate Administrators,
Regional Administrators, Laboratory Directors and
the General Counsel shall establish procedures
within their respective organizations to ensure
that information collection and reporting systems
under their direction are in compliance with this
policy.
While the value of obtaining locational coordinates
will vary according to individual program
requirements, the method, description and accuracy
of the coordinates must always be documented. Such
documentation will permit other users to evaluate
whether those coordinates can support secondary
uses, thus addressing EPA data sharing and
integration objectives.
7 . WAIVERS. Requests for waivers from specified provisions
of the policy may be submitted for review to the
Director of the Office of Information Resources
Management. Waiver requests must be based clearly on
data quality objectives and must be signed by the
relevant Senior IRM Official prior to submission to the
Director/ OIRM.
8. PROCEDPRES AND GUIDELINES. The Findings and
Recommendations of the Locational Accuracy Task Force
supplement this policy. More detailed procedures and
guidelines for implementing the policy are issued under
separate cover as the Locational Data Policy
:ion Guid*»lings.
IRM POLICY MANUAL 2100
-------
Please note that attachment 2 is forthcoming. It will be
sent to you under separate cover.
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Locational Accuracy Task Force
Findings and Recommendations
Prepared/or:
IRM Steering Committee
U.S. Environmental Protection Agency
Prepared by:
Locational Accuracy Task Force
U.S. Environmental Protection Agency
Jack McGraw, Chairman
December 13,1990
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Executive Summary
The Locational Accuracy Task Force (LATF), over a period of
six months, collected and weighed a considerable amount of
information on geocoding technologies and programmatic
requirements in order to reach the following conclusions:
More analysis needs to be done to determine the accuracy
and costs of geocoding methods, yet it is clear that the future
holds the greatest promise for GPS technology;
To achieve cross-media integration, some EPA programs,
regions, states, and other Federal agencies have already
taken significant steps to develop a locational accuracy
policy;
Unless a clear goal is stated, the data in the Agency's data
bases will continue to be a "mixed bag";
A strategy is needed to help individual programs comply
with the proposed recommendations;
No matter which geocoding method is chosen, the high costs
of equipment, training, and data collection will make the
implementation of a standard expensive for the Agency;
Acquiring or updating locational data for old data in order to
meet a standard will be too costly and difficult;
Incentives, such as technical transfer and data sharing with
state and local governments, will be more effective than
enforcement measures in attaining accuracy goals;
Steps must be taken immediately to populate FINDS with
locational coordinate data using the most reasonable method
available; and
The consensus of the LATF is that accurate locational data is
essential to risk management and multi-media decision
making.
These conclusions led the LATF to formulate five
recommendations for the IRM Steering Committee:
1. Establish a 25 meter goal The Agency should set a 25
meter or better (±1.0 second) level of accuracy. This goal
would apply to new data only. New data is considered that
which is collected after the policy is enacted and would
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EXECUTIVE SUMMARY
include data collected by site visits, supplied by facilities, or
collected to support special programmatic needs.
2. Set GPS as the standard The Agency should set Global
Positioning Systems (GPS) technology as its standard. The
Agency should concentrate on the large scale acquisition of
equipment and on providing training. In the short term, the
Agency should support map interpolation.
3. Define a deviation process The Agency should define a
process for programs to request exemptions from the policy.
Using the Data Quality Objectives (DQO) process, programs
obtain a waiver from either the latitude/longitude policy
itself, the accuracy target, the method of data collection,
and/or the time schedule by applying to the IRM Steering
Committee or some other decision-making official or body.
4. Pursue incentives The Agency should pursue incentives
rather than enforcement actions to achieve the target
accuracy. The LATF has identified 8 financial incentives
and 3 information incentives for this purpose. The financial
incentives are: resource "reserve pools," "tapping"
resources, new grant conditions, fiscal year carryover funds,
supplemental funds, fees for data use, State/EPA Data
Management grants, and state grants. The information
incentives are: State/EPA data sharing, public/private
partnerships, and common ground with regulated facilities.
5. Upgrade FINDS The Agency should upgrade FINDS,
using address matching to populate the data base with
locational coordinate data. The cost of the effort is estimated
at this time to be $2 million. The accuracy of the locational
data in FINDS would improve as individual programs
update the data base. EPA should also pursue the "gateway"
concept to allow FINDS to link with program data bases.
The next steps for the Agency are to:
Develop a strategy to communicate the changed policy to the
environmental community, especially states;
Complete work begun by OIRM on guidance for
implementing the policy;
Pursue issues of: funding, security, quality assurance,
incentives, and upgrades to EPA data bases; and
Develop a plan to revisit the locational accuracy issue in 18-
24 months.
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Chapter 1: Recommendation #1:
25 Meter Goal
The first recommendation of the Locational Accuracy Task Force is
that the Agency establish a 25 meter goal for locational accuracy.
This means that latitude/longitude coordinate data for a site should
be accurate to within 25 meters (±1.0 second).
FPA programs are expected to develop a strategy for meeting the
25-meter goal as expeditiously as practical, but in no case later than
January 1, 1995, for all new and routinely updated computerized
records.
In order to better understand the LATF's recommendation, this
first chapter describes the following:
Why 25 meters?
Why a goal and not a standard?
What is new data?
What does 1995 mean?
The benefits of the goal
Issues and obstacles to implementation.
Introduction
The LATF, over a period of six months, collected and weighed
considerable information on geocoding technologies and
programmatic requirements for locational data. With this
information, the LATF formulated the five recommendations
reported in this document. This next section provides an overview
of some of the analysis that went into those final recommendations
and provides further detail where deemed necessary.
Why 25 meters?
The LATF, when deliberating on a target accuracy for the
Agency, considered the following:
What is a reasonable level of accuracy, given the status of
current program requirements, current technologies, and the
costs of implementation?
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RECOMMENDATION #1: 25 METER GOAL
What level of accuracy is or will be needed to support critical
Agency decision-making functions, such as risk
management?
In response to the first question, the LATF surveyed 25 EPA
programs to determine their current or planned policies for the
collection of locational data. [See LATF: Acceptability Report:
Program Offices for more information.] Eleven of these programs
already require 25 meters (±1.0 second) or better accuracy. A
second survey which evaluated six geocoding methods (explained
later) found 25 meters to be within the range of accuracies for field-
based (i.e., conducted in the field) geocoding methods. The costs
of implementing the most accurate of these methods will be high,
since the Agency regulates or is interested in nearly 1,900,000 sites/
facilities (assuming no cross-regulation).
In response to the second question, the LATF agreed that
achieving a base of accurate locational data (e.g., 25 meters) is as
important as achieving a base of locational data at the same level of
accuracy (e.g, all data at 100 meter accuracy). The latter condition is
necessary to develop a common basis for the comparison and
evaluation of locational-based data and cross-media support
environmental analyses.
The LATF arrived at its final recommendation by balancing the
need for a feasible target or standard against the need for data as
accurate as possible in order to support the Agency's mission.
Why a Goal and not a Standard?
The preliminary results of a LATF study of geocoding methods
produced some interesting results. In this study, the accuracies and
associated costs of six methods were analyzed: address matching,
map interpolation (office-based, field-based, and rectified
photograph). [See Current Methods for Determining Locational
Coordinates (Version 2.0) for a description of these methods.]
The study showed that all six methods exhibited wide
fluctuations in levels of accuracies under certain conditions. Even
Global Positioning Systems (GPS) may produce results outside of
the target accuracy if satellites shift or if the Department of Defense
downgrades the signals for reasons of national security. The truth is
that there is no realistic way to ensure that reported coordinates are
within the targeted range of accuracy unless they are compared to
known reference points.
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FINDINGS AND RECOMMENDATIONS OF THE LATF
Due to this fluctuation in the levels of accuracy using various
geocoding methods, a standard measurement such as ±25 meters
would be unenforceable. At best, the Agency can only choose a
standard technology which produces accurate readings under typical
conditions. The Agency must then implement that technology into
its operations in such a way as to ensure the best results.
It is for these reasons that the Agency has chosen a goal of
attaining high-quality, accurate locational data, rather than a
standard. The LATF has chosen GPS technology, proven to be the
most feasible yet accurate means today of determining
latitude/longitude coordinates, to be the standard (see Chapter 2). It
is the intent of the LATF that the Agency's programs employ this
technology to move towards the stated goal.
What is New Data?
The LATF recommends that the locational accuracy goal apply to
all data collected after the policy becomes effective. The most recent
data will have the greatest potential for immediate impact on
decisions; therefore, new data should have the highest priority for
compliance with this goal.
Old data need not be brought up to the new accuracy standard
until a specific objective exists to justify the effort. If there is a need
for applying the new accuracy goal to old data, it can be done in
several ways:
1. Collect the new data at the accuracy target during regular site
visits;
2. Require compliance with the new target upon normal re-
permitting; or
3. Collect the data for specific needs by visiting sites or hiring a
contractor to provide the information.
What Does 1995 Mean?
An objective of the LATF recommendations is to allow program
offices to begin implementation of the Locational Data Policy in a
manner that it considers technically and fiscally responsible, within
certain boundaries. To minimize boundary excursions, a "deviation
process" will need to be established and implemented (see Chapter
3). This process requires a clear statement of what locational data
standard the program office intends to meet and the timeframe and
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i: RECOMMENDATION #1: 25 METER GOAL
procedure (eg.; address matching, map interpolation, or GPS) that
will be employed to meet that standard.
Approval of deviation applications will initially be responsive to
practical near-term needs of program offices, but approval will
become markedly more difficult as January 1, 1995 approaches,
and virtually impossible thereafter.1
Program offices will be encouraged to begin filling the
"location" data element within their data base by appropriate means.
Later, as a facility's permit is up for renewal OR as it is undergoing
a periodic inspection, an approved geocoding method such as GPS
should be used to acquire new location data and replace old data in
the applicable data bases.
1 After January 1, 1995 the deviation application process will be much more
rigorous. It is believed that by then all locational data entered into a system
should meet the <=25 meter standard. The satellite system supporting GPS will
have reached its full complement of 24 satellites by June 1992 or earlier. In
addition, this policy will have impacted the Agency's budget process in a
significant manner in both the FY93 and '94 budget request cycles (along with
the modest beginnings in FY91 and reprogramming in FY92).
Benefits of the Goal
The most important benefit of implementing a 25-meter goal for
locational accuracy is that it will result in a common basis for the
comparison and evaluation of all of EPA's program data. With this
basis the Agency can achieve truly integrated environmental
analysis, planning, and management.
Presently, all EPA programs except OSWER have regulatory
requirements for the use of latitude and longitude designators.
(OSWER has specific, non-regulatory program directives.)
However, there is no common required accuracy for latitude/
longitude specification amongst the various programs. Hence, the
least accurate data become the common denominator for all
evaluations in which those data are used. The limits of this least
common denominator decreases the reliability of any evaluations.
There will be many other benefits to implementing the LATF
recommendations. Some of these benefits we are realizing already;
others will come later. For example, the data from all programs will
be able to be presented on maps, allowing the visual association of
pollution sources to their potential impacts on environmentally
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FINDINGS AND RECOMMENDATIONS OF THE LATF
vulnerable sites such as water supplies, wetlands, spawning and
nesting locations, recreation areas, and population centers. That
kind of information will become an increasingly valuable tool for
defining environmental priorities, targeting monitoring and
compliance programs, and fashioning future strategic plans for
protecting environmentally threatened areas.
Besides those uses, the Agency's Geographic Information
System (GIS) capability has proven to be a masterfully effective
way to explain to the public, legislators, and the media the extent
and location of environmental problems. GIS tools may also be
used to evaluate the extent of environmental improvement under
varying management scenarios.
Issues and Obstacles
The path to implementing the LATF recommendations is not
without barriers programmatic needs differ, costs are large, some
existing data bases need modification, definitions must be uniform,
and training must be accomplished. In addition, preliminary
estimates put the cost of implementing a standard at well over $50
million.
Another major obstacle to implementing the LATF
recommendations is the need to consider the reporting burden of the
Agency's regulated entities, both in terms of gaining Office of
Management and Budget approval, as well as in terms of the
feasibility and fairness to reporters.
The LATF recognized these factors and has thoroughly weighed
them in formulating its recommendations.
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Chapter 2: Recommendation #2:
GPS Standard
The Locational Accuracy Task Force is recommending the adoption
of a technology-based standard for locational accuracy. This implies
that global positioning systems (GPS) will be the technology of
choice for achieving accuracy goals. However, there are a number
of issues associated with a GPS-based standard that need to be
addressed in order to undertake an Agency implementation.
Present and Future State of GPS
Technology
The NAVSTAR Global Positioning System is owned, operated
and maintained by the U.S. Department of Defense. In its fully
deployed status, it will consist of 28 satellites in independent earth
orbit. Each satellite broadcasts two kinds of radio signals on pre-
assigned frequencies: the C/A-code and P-code. Earth-bound
receivers may be used to acquire at least four signals to determine a
location in latitude, longitude and elevation coordinates using
mathematical and doppler solutions. When fully deployed, the
system will be able to provide 25m minimum accuracies for
navigation units (C/A-code receivers), 24 hours per day. There is
reason to believe that actual accuracies will be <10m in most
situations.
A much more precise GPS unit is the geodetic device (P-code
receivers). Since these units receive a much more complex signal
and are capable of receiving more than four satellites at a time, much
higher accuracies are obtainable. When fully deployed, the system
will be able to provide centimeter-level accuracies.
Currently, 18 satellites are deployed. This limits the acquisition
of satellite signals and has implications on the accuracy and
availability of GPS data. Our studies have shown that there is a
high degree of variance introduced if a receiver shifts "lock" from
one set of satellites to another. Because of limited availability,
significant time must be spent in pre-survey activities, planning
location acquisitions around satellite visibility.
The military reserves the right to selectively degrade or even
deactivate the system at any time to protect national security
interests. Degradation (termed selective availability) implies that the
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FINDINGS AND RECOMMENDATIONS OF THE LATF
satellites signals are programmed to provide erroneous locations to
earth receivers. However, DOD "guarantees" that 100m accuracies
will still be achievable, even under selective availability. Selective
availability may be overcome by the use of two receivers for
differential correction and the use of post-processing software.
Conclusion
The GPS satellite system is not fully deployed at this time, and
this has implications on the current use of the technology.
However, based on our limited studies, it shows potential to
reasonably achieve 25 - 100m accuracies with adequate precision
and repeatability under optimal conditions in its present deployment
status. There is every reason to believe that, with final deployment
of the constellation in mid-1992, GPS may achieve <10m accuracies
with high precision and repeatability.
Assumptions
The above conclusion is based on the following assumptions:
The use of multiple GPS receivers for differential correction
is necessary to overcome the effects of inadequate satellite
coverage and military degradation of the signal.
Optimal conditions implies that the GPS unit is receiving
four satellite signals with good satellite-to-receiver angles
and little-to-no influence from weather conditions,
topography, or external radio noise.
GPS is not a stand-alone technology. More often than not,
a field person is using other information sources such as
maps and aerial photos to locate themselves for GPS data
acquisition.
An experienced user implies that a trained user is operating
the receiver in the field and performing the necessary post-
processing steps in the office.
Concerns
The following concerns will need to be addressed to fully exploit
the utility of GPS:
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i: RECOMMENDATION #2: GPS STANDARD
What is a facility? The issue of repeatability becomes a
major concern without a clear definition of a facility. Most
often programs are interested in point data, but what point?
Front door? Centroid? Outfall? There will be a number of
occurrences where a facility will have multiple regulated
entities on the property, with multiple reporting
requirements.
Real-time correction Under selective availability, it is
possible to offset the introduced error by using two receivers
for differential correction. While the majority of our data
collection may be served by post-survey support, there will
be times when an accurate location is necessary in the
present timeframe. Examples such as returning to a pre-
determined, unmarked sampling location or emergency
response situations come to mind. In these scenarios, it may
be necessary to establish a radio link with a base station,
allowing for real-time corrections to be passed via the radio
link.
What types of receivers and how many? There are several
vendors entering the market with a wide range of prices for
their units. C/A-code navigation units range from $3-15 K,
while P-code geodetic units start at $30K. Will low cost
units be adequate for Agency use, given our accuracy
targets? How many of the geodetic and navigation units are
necessary per Region?
Effective use of community networks A community
network implies that there is a centralized approach to
managing GPS correctional data. Regions I and VII have
advocated the deployment of central geodetic units for
continuous logging of GPS data. These data sets could then
be used to differentially correct navigation unit data and
thereby offset the effects of selective availability and highly
variant data. While this sounds like a solid solution, very
little is known about the effective range of community
networks. The effects of topography, microclimate and
radio noise sources may need to be studied at a regional level
before implementing community networks.
Training In its present state, GPS is not a "push button"
operation. Users need to be adequately trained in pre-
survey, survey, and post-survey operations. The operator in
the field must be constantly aware of signal strengths,
satellite horizons, noise sources, and topography. When a
survey is completed, there is a tremendous amount of data to
be sorted and screened before an optimal locational solution
is determined.
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FINDINGS AND RECOMMENDATIONS OF THE LATF
Utility Currently, there is a lack of software tools for the
sorting/screening of GPS data during post-processing. The
vendor community is responding, b ut the user community
may be the best source of GPS data utilities.
Implementation Issues
The above assumptions and concerns have direct bearing on a
national implementation of GPS within the EPA. We have identified
several steps that need to be addressed:
Policy determinations A clear definition of a facility is
necessary.
Requirements analysis Define the following:
- How many units are needed per Region? Several of the
EPA Regions have identified the need for 5-7 navigation
units and 1-2 geodetic units per Region. There is every
reason to believe that the states will interpret the Location
Data Policy (LDP) as an EPA requirement that will
necessitate an increase in grant funding to states to meet
the requirement. Dennis Kirk surveyed three states and
found that they foresee a need for 20-30 navigation units
per state.
- What types of units are needed for each Region? What is
the mix of C/A-code and P-code receivers necessary for
a Regional implementation?
- There is a standardized data exchange format that would
promote compatibility between manufacturers'
equipment. However, some manufacturers may not
subscribe to the data elements necessary to promote
exchange. In addition, the exchange program has not
been ported to UNIX platforms and has not been tested
by EPA.
- What is the role of community networks? Could the
EPA Region be the central repository of GPS data for
use by states? This might help offset the state concerns
about the LDP requirement without adequate support
from the Agency. What is the minimum equipment suite
necessary to support a central GPS repository? What is
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i: RECOMMENDATION #2: GPS STANDARD
the effective range of community networks under various
conditions?
How do we obtain GPS training? Do we fill the training
need internally or via vendor? What are the necessary
fundamentals for any curriculum?
What is the need for real-rime locarional accuracy? How
often and under what circumstances will we need to
know where we are, right now, with no induced
inaccuracies? The definition of this element will
determine the number of radio transceivers necessary for
real-time correction.
How soon can we define and document standard
procedures for pre-survey. survey, and post-survey
GPS activities? EMSL-LV has begun this process with
the drafting of the GIS primer (now in review).
However, with advances in the receiver technology and
absorption of case studies, this documentation will have
to be revised and updated.
Equipment Costs
I have estimated the cost of a typical Regional GPS suite of
equipment with the following assumptions. A Region wishes to:
Maintain a central repository of GPS correctional data;
Maintain a community network;
Have adequately trained personnel; and
Maintain 5 navigation units for field work.
COST OF A TYPICAL REGIONAL GPS SUITE
Cost of central unit to support community network:
- 1 geodetic P-code GPS receiver $50K
1 dedicated Sun Spare 1+ workstation with
adequate storage and data archival capability: $45K
10 days of training (including travel, per diem,
salary and fees): $ 1 OK
Purchase of 5 field units: $70K
TOTAL ESTIMATED COST: $ 170K
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FINDINGS AND RECOMMENDATIONS OF THE LATF
NOTE: This estimate does not account for any purchases by the
EPA for use by the states.
Final Cautions
We would caution the Agency against total dependence upon
GPS technology. As promising as it appears, DOD Assistant
Secretary of defense for Command, Control, Communications, and
Intelligence has continued to state the need to retain the ability to
degrade the signal or completely deactivate it for national security
reasons. The Agency must not loose sight of the need to maintain or
increase proficiencies in the use of other technologies for locational
determination. Our studies have shown that simple map
interpolation has the potential for achieving a 25m accuracy when in
the hands of an experienced map user, additionally, address-
matching capabilities will continue to improve as vendors respond to
the need for highly accurate address data.
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Chapter 3: Recommendation #3:
Deviation Process
The third recommendation of the Locational Accuracy Task Force is
that the Agency define a deviation process for the Locational
Accuracy Requirement.
Waiver Policy
In the locational accuracy policy, the Agency needs to:
Establish criteria by which to evaluate, and to grant or deny,
waiver requests for exclusion of each individual data
collection activity from (1) the locational policy in general,
and (2) the locational accuracy requirements in particular.
Be uniform in the execution of the waiver process.
Assure that agency-wide locational coordinate objectives are
being accommodated and considered in data collection.
Purpose of Having a Waiver Provision
The purpose of having a waiver provision is to:
Give the Locational Accuracy oversight group an
opportunity for reasonableness about the implementation of
the locational data accuracy requirement;
Demonstrate a sensitivity to the challenge faced by program
managers to adapt to the accuracy requirement;
Establish an approach and mechanisms for enforcement of
the locational data accuracy requirement;
Provide an orderly, structured process to ensure consistency
with the 25 meter locational accuracy goal by the 1995 target
date;
Ensure that progress toward the locational accuracy goal is
attentive to, and driven by, data quality.objectives;
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FINDINGS AND RECOMMENDATIONS OF THE LATF
Maximize effective use of existing technology while the
Agency builds Global Positioning Systems (GPS) capability;
and
Have an effective process for identifying Agency data
collection efforts which reasonably should not be subject to
the locational data policy and minimum locational accuracy
standard.
Waiver Process
To incorporate into Data Quality Objectives (DQO) process a
demonstration of necessity of a waiver from the locational data
policy and/or accuracy requirement that:
Describes the objective of the data collection effort and
contrasts it to Agency objectives for locational data accuracy.
Defines an approach to meeting the locational data accuracy
objectives for the data collection effort (and how it deviates
from the Agency-wide requirement.
Provides a justification as to why the Agency-wide locational
data (and accuracy) is infeasible for this particular data
collection effort including cost
The program requesting a variance from the locational policy
or accuracy target would prepare an individual petition for a
particular data collection project.
Submitting/Approving Waiver Requests
All waiver petitions are to be reviewed/approved by a
subcommittee appointed by the IRM Steering Committee. The
subcommittee would be composed of 3 to 5 members of the
Locational Accuracy Task Force, and represent policy, technical,
and media program interests.
The final waiver provision should specify the composition of the
subcommittee, and it is felt that at least three of the subcommittee
members should be from the program media.
The Program commits to preparing a written request for waiver
containing appropriate arguments and documentation. The written
waiver request with supporting documentation is submitted to the
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3: RECOMMENDATION #3: DEVIATION PROCESS
subcommittee, signed by the Program's Senior Information
Resources Management Office (SIRMO).
Decisions of the subcommittee are subject to review by the IRM
Steering Committee. An annual report to the Steering Committee is
due to review program policy effectiveness.
Requirements of the Waivers and Procedures
for Granting Them
Waiver requirements should encompass all the criteria for
granting a waiver. For example, has the Program documented cost
of implementing the locational data policy and accuracy standard?
(1) Develop Procedures for Granting or Denying
Waivers, including:
A definition of roles and responsibilities (who must prepare
the waiver request, who reviews it, who has final authority,
etc.) of processors.
A definition of enforcement mechanisms, and the roles of the
"enforcers," both at the HQ level and in the field.
(2) Definition of roles and responsibilities of
applicants, including:
Timing of waiver request submissions and
approvals/disapprovals.
(3) Program implementation plans:
All waiver requests must be specifically tailored for
individual program element data collection efforts, and must
contain both the rationale behind the requested variance and
specific Data Quality Objectives (DQO's) for the data for
which the variance is being requested.
The waiver should include reasons why the locational policy
can't be met, such as resources, program regulations,
applicability of lat/long data, and alternate sources of lat/long
data (i.e., Construction Grants can obtain lat/long data from
PCS if data linkages between data bases are in place).
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FINDINGS AND RECOMMENDATIONS OF THE LATF
All waiver requests should address the overall Agency plan
for achieving consistency with the locational goals.
Criteria for Granting a Waiver
The criteria for granting a waiver should be:
Has a program thoroughly analyzed and documented its
needs for locational data? Are all primary uses of the data
well understood?
Has the program solicited input from secondary users of
their data? (This will help to ensure that Agency-
wide/multimedia requirements are incorporated into the
locational data requirements of individual programs.) Are
the data intended for single purpose objectives not relevant to
more general or multimedia applications?
Is the program mainly concerned with facility level data as
opposed to entity level data (i.e., pipes, stacks, wells, etc.)?
A singular locational reference for a regulated facility should
not be required to support 2.5 meter locational accuracy. On
the other hand, entity level data generally should support 25
meter accuracies for locational data.
Has the program documented the expected cost of
implementing the locational data policy and accuracy
standard? Has the program identified where this burden lies
(i.e., Headquarters, Regional Offices, States, the regulated
community)?
Note: Burden Cost should not be a deciding factor in a waiver
decision. However, it should be taken into account when
developing a phased implementation program.
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Chapter 4: Recommendation #4:
Incentives
The fourth recommendation of the Locational Accuracy Task Force
is that the Agency pursue incentives for locational accuracy.
Short Term Resource Policy
Recommendations
As a portion of the recommendations, task force representatives
agreed unanimously to include financial and informational
incentives. The attachment. Resource Policy Options for Location
Standards Implementation, lists and describes various options which
could be used separately or collectively depending on the particular
data base affected.
Because of the magnitude of accumulating and maintaining
highly accurate locational data, we need to look at creative ways of
leveraging resources as well as investing additional EPA resources.
Several of the options listed provide incentives to State and local
governments and the private sector to assist in defraying the costs of
meeting more exacting EPA locational standards.
In addition to incentives to external entities and overall
implementation, the task force discussed providing internal
incentives to offices which accelerate implementation of locational
data standards in their data bases. One way to do this would be to
hold funds either in the Administrator's Office or with the OIRM to
reward offices during the year as they brought their system into
compliance. Such an approach would require the OIRM Steering
Committee to establish and monitor the standards upon which these
incentive funds would be distributed. The Steering Committee
should consider pursuing making such incentives available.
The task force also felt that a Reilly/Habicht endorsement of this
policy was essential for its success. To initiate planning for meeting
the goal in FY 1995, we recommend that locational data be included
as an item for discussion in the Administrator's February kick-off
planning meeting for FY 1993 with the Assistant Administrators
(AAs) and Regional Administrators. The inclusion would not only
highlight the issue of locational accuracy in data bases, but it would
also focus all of EPA's senior management on assessing the
A-24
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FINDINGS AND RECOMMENDATIONS OF THE LATF
resource needs and impacts on their information providers and users
for better locational accuracy. The AAs could be asked to include in
their plans how they will address the issue in FY 1992 through the
target fiscal year of 1995. This would better define the Agency's
ability and commitment to implementing this policy.
Among the options on the attachment the task force recommends
as the most realistic to consider, though all require either internal or
external approval and/or development, are creating resource reserve
pools, establishing new grant conditions, using State/EPA data
management grants, providing better information products and
support infrastructure for locational data, and promoting
Public/Private Partnerships.
"Early" Incentives for Achieving
Better Quality Locational Accuracy
There are a range of financial and other incentives available for
achieving better quality locational data. The financial incentives
which appears most viable for "early" implementation include:
"Tapping" resources, including Agency-wide, media or
program-specific taps;
Requesting special supplemental funds;
Creating resource "reserve pools" from existing state grant
program funds;
Imposing new grant conditions in existing state grants;
Initiating state grant "givebacks;"
Earmarking fiscal year carryover funds;
Establishing a "fee" system for data access and use; and
Funding through S tate/EPA Data Management Grants.
The "information" incentives are based upon the increasing value
of locational and other environmental information to public and
private sectors. These incentives reflect the reality that no one
organization by itself can achieve complete and accurate information.
Cooperation and stewardship in managing information are essential.
-------
4: RECOMMENDATION #4: INCENTIVES
The most promising information based incentives for early
implementation are:
Information products to foster State/EPA data cleanup,
sharing and decision making;
Business opportunities for third-party, value-added
environmental information providers (public- private-
partnerships);
Mutual benefits to all parties (EPA, State, regulated facilities
and the public) of using good information; and
An EPA infrastructure to support the Nationwide collection,
processing and dissemination of environmental locational
data.
Financial Incentives
The following paragraphs provide a brief description of each
policy option and are not listed in a recommended priority of use:
Tapping Resources This option is common Agency
practice for funding special interest, unfunded programs.
Funds would be drawn off affected EPA offices on a to-be-
determined basis and channeled into areas necessary to
implement the policy.
Supplemental Funds The Agency could request additional
special funds for this activity from OMB if the need for
funds did not coincide with regular annual budget
submissions.
Resources Reserve Pools The Agency could look into the
option to "reserve" a portion of each state grant program's
funds, and dedicate the resulting "pool" of funds specifically
to this activity. Interested states could opt to perform the
activity, increasing their state grant funds from the pool.
Grant Conditions The Agency already funds the states to
implement information management activities in existing
state grant programs. The Agency could insert a new
condition into all of its grants requiring states to perform this
activity with existing funds.
Grant Givebacks The states could fund this activity from
existing grant funds by "giving back" a portion of their
A-26
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FINDINGS AND RECOMMENDATIONS OF THE LATF
grants to the Agency to perform this activity for them. The
states would request the Agency to deobligate grant funds to
carry out specific activities for them.
Fee System The Agency could establish a fee to be paid
by potential users of the data base, if the information has
value to private industry. The fees collected could be used to
fully or partially fund states' implementation of the system,
depending on the amounts collected.
State/EPA Data Management fSEDIvn Grants This new
grant program begins in FY 1991. It could be used to
partially fund some initiatives (e.g., staff, equipment,
contractor support, central services, data, etc.) to improve
the collection, quality, use and dissemination of locational
data.
The financial options above could be executed in combination,
using existing Agency program authorities; however, there may be
special considerations for each option or combination of options,
depending upon specific dollar amounts and other operating
requirements. Some of these considerations might be:
Notification to the Appropriations Committees for
reprogramming actions that exceed ceilings;
Grant deviations for exceptions-to formula-driven state grant
programs;
Legal determination of an appropriate use of Trust Fund
accounts;
Federal Register notices or. other public notification
processes; and
Office of Management and Budget (OMB)/Treasury approval
of new accounts.
Depending upon the financial options selected, elements of
Office of Administration and Resources Management (OARM),
CLA, Office of General Counsel (OGC), and the media National
Program Managers (NPMs) would need to fully explore and
develop a comprehensive resource strategy, assuring that practical,
legal, and other necessary approvals are obtained.
A-27
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4: RECOMMENDATION #4: INCENTIVES
Information Incentives
The following paragraphs provide a brief description of each of
the information incentives listed above:
Information Products for State/EPA Staff The State/EPA
Data Management Program demonstrates that information in
itself can be a strong incentive for cooperative data
management efforts. Both EPA and the States have a
common need for accurate locational data for organizing and
analyzing environmental data.
Locational data is best collected and verified as close as
possible to the local level (e.g., State field office personnel,
regulated facility), but incentives are needed to secure local
support. Aside from using regulatory and fiscal incentives,
providing environmental information for free that is useful at
the local level can be a good incentive. This will necessitate
some rethinking of the near term priorities and information
products of EPA's State/EPA Data Management (SEDM)
and GIS Programs.
Effort should be placed on developing relatively simple,
PC based, "downloaded" GIS and EPA data base products
(e.g., Facility INDex System (FINDS) or Hazardous Waste
Data Management System (HWDMS) Inventory Report, a
GIS-like, 8 1/2 x 10 USGS Quad Map overlay of locations
of regulated facilities) that are useful at the local level.
These products should support locational data cleanup as
well as local decision-making. CD ROM is a promising
technology that could be used in the future to disseminate
large quantities of information, particularly GIS data. The
same PC diskette and CD ROM based products could also
enable EPA to provide better public access to environmental
data.
Business Opportunities For Third-Party Information
Providers EPA should consider public/private
partnerships to foster growth of third-party, value-added,
environmental information providers. There is growing
interest in business opportunities in this area. For example,
law firms conducting property title searches, investors
considering land acquisitions and the financial industry
considering mortgage loans are asking EPA through the
Freedom-of-Information Act (FOIA) for information and
locational data for properties that may have environmental
A-28
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FINDINGS AND RECOMMENDATIONS OF THE LATF
liabilities. Therefore, EPA and State information has
commercial, economic value.
EPA has a near term need for locational data in urban
areas based upon street address matching. Rather than pay
a company such as Dun & Bradstreet or Donnelley
Marketing to do address matching, EPA should explore
partnerships that "trade" address matching services for
"FOIA" services (e.g., environmental information).
EPA is limited in its ability to respond well to many of
these types of information requests under FOIA, yet EPA is
a sole source of some key information. Companies may see
a new market for their information services by offering
added value to what EPA would normally provide in filling a
FOIA request There is opportunity for EPA (and States) to
save resources that will be needed to meet the ever growing
FOIA workload.
Mutual Benefits To All Parties Of Using Good Information
Our recent experience with the Tide in Toxics Release
Inventory (TRI) demonstrated the benefits and problems of
public dissemination of environmental data. There is clearly
a mutual benefit to EPA and the regulated community of
providing the public and private sectors with good
information. The EPA regulated community may be
reluctant to provide information in general, but it is in their
overall self interests to be sure accurate information is being
used. The locational data for their facility is no exception.
The regulated facilities could provide locational data in
several ways. They can mark-up U.S. Geological Survey
(USGS) topographic maps provided by EPA and mail them
to a central point for determination of coordinates. EPA's
Office of Waste Programs Enforcement (OWPE) is using
this approach for 7200 National Pollutant Discharge
Elimination System (NPDES) major dischargers. Another
possible option is to submit an official land survey for the
facility with key points (e.g., center of primary facility,
discharge pipe, etc.) identified. More homework is needed to
explore this approach. In either case, EPA would need to
provide an infrastructure to determine coordinates, process
them into a data base and provide GIS output for coordinate
verification.
Provide Infrastructure For Processing & Disseminating
Locarional Data Achieving good quality locational data
requires an infrastructure to provide data conversion,
maintenance, integration and dissemination. Conversion is
A-29
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4: RECOMMENDATION #4: INCENTIVES
the process of taking an annotated map, property survey,
etc. and determining latitude and longitude coordinates.
Maintenance is the process of input, verification and revision
of locational data in the numerous EPA data bases.
Integration is the process of pulling together and comparing
data to save redundant data collection and to also crosscheck
data quality. Dissemination involves both the process of
returning the data to the originators for verification as well as
making the accurate data widely available.
Some of this infrastructure may best be handled by a
central Headquarters or Regional staff with proper
equipment (e.g., digitizer, GIS workstations) and
specialized training (e.g., to input to EPA systems, to
crosscheck facility data via FINDS). An example would be
the CSC contractor support teams for FINDS data
maintenance and the OWPE contractor support for
converting Permit Compliance System (PCS) "Majors"
coordinate data.
Aside from the "processes" part of the infrastructure,
there is also a need for technical assistance, equipment and
information products for managers and staff involved in
acquiring accurate locational data. The information products
include not only GIS like products but also current policy
and guidance documents, reference material and reports from
EPA data bases (e.g., TRI, PCS, HWDMS, Comprehensive
Environmental Response, Compensation, and Liability
Information System (CERCLIS), FINDS/FACTS).
EPA should consider providing as much of this
infrastructure as possible as a way of encouraging and
supporting locational data collection and verification at the
local level.
A-30
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Chapter 5.* Recommendation #5:
FINDS
The fifth recommendation of the Locational Accuracy Task Force is
that the Agency upgrade FINDS.
Introduction
With the significant investments being made in locational
information across EPA's many programs we need to insure that
FINDS is poised to serve as the information utility for providing the
environmental community and the public access to this very
important data resource. Access to EPA's environmental location
and basic identification data must be viewed as an incentive to get
the non-EPA community to share their valuable spatial information
resources with us.
To complete the daunting effort needed to develop the refined
spatial data to conduct GIS projects, every group must do and then
share its part. EPA must pay its spatial data dues by creating and
maintaining a vigorous, viable, nationally supported system able to
act as a gateway to all our facility, discharge and other
environmental entity data. This is not a trivial task. However,
failing to address this need will result in many separate,
disconnected, likely incompatible systems being built. Extremely
poor data access, and great difficulty in doing the data cross
checking needed to insure continued data integrity would be the end
result.
We cannot on one hand ignore the need to seriously deal with
FINDS, and on the other hand make the significant resource
investment needed to collect and quality control our spatial data as
proposed by the LATF. Nor can we continue to "squirrel away"
these data in separate unsupported systems.
Vital EPA and state integrated applications above and beyond
GIS uses are at stake here including: tracking multi-media inspection
activity, implementing multi-program enforcement, conducting risk
assessments, and providing simple access for our states tc
application and permitting information.
Two key issues regarding FINDS and the agency's direction on
locational accuracy need to be resolved: 1) how should FINDS be
-A-31
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5: RECOMMENDATION #5: FINDS
enhanced to support the planned EPA and state efforts collecting and
using locational data? and 2) are there ways that the existing data in
FINDS can be used with techniques like address matching to
provide a quick start on making good, comprehensive locational data
available at least at the EPA regulated facility level?
Retooling the FINDS System
There is an OIRM initiative underway now to modernize
FINDS. It must be expanded to consider and then tackle these
issues in more than a superficial way. FINDS needs to be treated as
a mainstream, "serious" system like Aerometric Information
Retrieval System (AIRS). The GIS community needs to be actively
drawn into the requirements analysis.
The current FINDS system was not designed to address our
existing location data needs only a single latitude longitude can be
tracked at the facility level. For example the capability does not exist
to handle locational data at the discharge or operable unit level
although tracking these entities have become critical to many GIS
applications. FINDS also needs added system edit facilities to help
users spot changes in program system information to identify major
facility and discharge status changes and possible data errors. It is
recommended that the role of FINDS be analyzed in the context of
the locational data requirements perceived by the GIS community
and other locational data users.
Opportunities for drawing in related efforts that are logical parts
of the overall solution include fusing into a single project the FINDS
efforts along with important work now underway in the Software
Development Center's "Gateway Project". This project seeks to
provide access and sorely needed data browsing and data integration
capabilities, through a common user interface, to the major national
systems. The gateway would in part rely on FINDS to provide the
facility reference information for linking to the major program
systems like PCS and AIRS.
Another possible opportunity that needs to be reviewed is the
use of Structured Query Language (SQL) database technology for
delivering the sophisticated data model and performance likely to be
needed to meet added FINDS requirements.
We also need to consider the impact of collecting refined
locational data on the individual national program systems. Most
(not all) systems can store facility locational data. Some systems
A-32
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FINDINGS AND RECOMMENDATIONS OF THE LATF
(not more than a few) handle pipe/stack/operable unit level location
data. Work needs to be begun, with the national system program
managers, to insure that each system has the capabilities needed to
enter, store and deliver to the user the full range of locational data
being collected as we expand our location data efforts. This is a
major undertaking and must not be trivialized. Serious marketing,
by our most senior managers, must be done to convince the
individual Headquarters program managers that their best efforts are
needed here to provide these system changes. Media program
managers must get that message that they should commit the
resources to modify their systems not only to benefit their current
media data clients but also to allow the environmental community at
large to tackle data integration and risk assessments.
In some cases, FINDS may, as a last resort, have to house some
program data until the national system can be modified. In any case,
establishing ownership of collected location data by the appropriate
delegated group is key. Success in EPA developing and maintaining
solid locational information will only come when there is a well
understood partnership between the national system managers,
OIRM (in its FINDS information utility role) and the state and
regional locational data consumers.
FINDS and Facility Address Matching
The LATF discussed the potential of using address matching of
FINDS data to quickly generate quality facility data that would, until
replaced by more refined data, be available for the many spatial
analyses underway in the agency that require regulated facility
location data. The thought was to have OIRM explore the viability
of quickly filling the locational "holes" in FINDS, using a contract
service to tackle this significant effort on a national basis.
The contractor would work the FINDS address information
through a process that would check, and if needed, refine the
address syntax, then attempt an automated address match.
Reprocessing of those match rejects that looked feasible would also
be attempted.
We need to keep in mind that address matching is no panacea for
poor locational information. This technique would generally be
successful only for non-rural facilities. It would not be
recommended for facilities where good GIS or program system
locational information could be drawn upon. Also, there may be a
need for reviewing the address information before conducting the
address matching for a given facility. The bottom line is that while it
A-33
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5: RECOMMENDATION #5: FINDS
appears that address matching is worth pursing it will not by itself
be the total "cure" for the generally non-existent state of facility
location data. This technique needs to be thought of as one element
of a larger effort aimed at generating and maintaining quality
geocoded information for our inventory of regulated entities.
Overall Recommendations
The overall recommendations for FINDS are:
1. Retooling the FINDS System:
Recommendations:
Develop a project plan and begin requirements analysis to
address locational data needs (this would be carried out in
parallel with the on-going FINDS redesign);
Draw together FINDS and Gateway project efforts;
Define follow on steps for refocusing the FINDS/Gateway
system efforts using agency system life cycle methodology
to detail implementation options, cost-benefits etc.; and
Begin collaboration with program offices to address media
system changes required so they could support locational
data.
Cost Implications:
Added funding is required in FY 1991 and FY 1992 to
conduct the FINDS requirements analysis;
FY 1992 funding will be required to support accelerated
FINDS and Gateway development efforts; and
Program offices may need added financial support in FY
1991 and FY 1992, above their current base, to modify their
systems to handle refined latitude/longitude data and begin
related data cleanup and collection efforts.
A-34
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FINDINGS AND RECOMMENDATIONS OF THE LATF
2. Facility Address Matching:
Recommendations:
Develop a detailed methodology for address matching,
taking into account identifying and using existing
latitude/longitude data from some program systems and
selectively excluding FINDS records that are not true
facilities, e.g. RCRA Transporters;
Perform cost analysis and review external contract sources
for conducting address matching of FINDS addresses, based
on FINDS statistics; and
Develop a project plan and begin national facility address
matching efforts.
Cost Implications:
Funding to plan and then implement selective facility address
matching of FINDS addresses needs to be set earmarked for
both FY 1991 and FY 1992.
A-35
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Appendix B
CONTACTS FOR LDP IMPLEMENTATION ASSISTANCE
-------
Appendix B
Contacts for LDP Implementation Assistance
(January 1992)
ORGANIZATION
OARM/NDPD
OIRM/IMSD
OIRM/IMSD
OIRM/PSD
OIRM/PSD
OIRM/PSD
OPPE
ORD
ORD/EMSL-LV
EPIC
TOPICS
GPS Procurement
Data Administration
State/EPA Data Mgmt
National GIS Program
FINDS
GRIDS
Information Collection
Bequests
Data Quality
Objectives
GIS Center of
Excellence
Information Collection
Requests
NAME
JohijShirey
JeffSabol
Michele Zenoit
Tommy Dewald
Ingrld Meyer
Bob Pease
David Scbware
Nancy Wentworth
Mason Hewitt
Terry Slonecker
TELEPHONE NO*
0m 541-5730
(202) 260-8974
(202)260-5913
(703) 557-3083
(703)557-3145
(703) 557-3018
(202)260-2706
(202) 260-5763
(702)798-2377
(703) 349-8970
* To confirm phone numbers, call the EPA Locator at (202) 260-2090.
B-l
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..Vf.V.-.-f.-.-.V^'.'.'M^'AVS.VAV.-.VS.^V.'&WW
Appendix C
PARTIAL LIST OF FORMS RELEVANT TO LDP
-------
Appendix C
List of Forms by Program that Possibly Need to Be Modified
for LDP Compliance
Superfund Program
Form# Date Form Title
2070-11 (7/81) Potential Hazardous Waste Site-Site Inspection Report
(Site Identification)
2070-12 (7/81) Potential Hazardous Waste Site Preliminary Assessment
2070-13 (7/81) Potential Hazardous Waste Site-Site Inspection Report
2070-14 (7-81) Potential Hazardous Waste Site-Current Disposition
9100-1 (2/88) Technical Enforcement Support at Hazardous Waste Sites
9110-2 (8/88) Organic Traffic Report (for CLP use only)
9350-1 (1/90) Toxic Chemical Release Inventory Reporting Form
(FormR)
9510-1 (7/88) Substantiation to Accompany Claims of Trade Secrecy:
Emergency Planning/Community Right-to Know Act
3510-2B
3510-2C
3510-2D
3510-2E
3560-3
3560-4
7500-52
7500-53
Water Program
Date Form Title
(ND) NPDES Discharge Monitoring Report
( 8/90) Application Form 1-General Information-Consolidated
Permits Program
(6/80) Application for Permit to Discharge Information-
Consolidated Permits Program (Form 2B)
(6/80) Application Form 2C-Wastewater Discharge Information-
Consolidated Permits Program
(9/86) Application Form 2D-New Sources and Dischargers:
Application for Permit to Discharge Process Wastewater
(7/86) Facilities Which Do Not Process Wastewater
(3/85) NPDES Compliance Inspection Report
(2/80) Deficiency Notice-NPDES
(6/80) SPCC Inspection Summary Sheet
(9/80) SPCC Inspection Field Sheet
c-i
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Form#
7500-55
7500-60
7520-6
7520-7
7520-8
7520-9
7520-10
7520-11
7520-12
7520-14
7530-1
7550-6
7550-22
7550-23
Form#
7710-3C
7740-5
7710-35
7710-52
7710-53
7740-21
Date
(1/89)
(3/87)
(10/85)
(9/90)
(9/90)
(2/84)
(9/90)
(9/90)
(9/90)
(9/90)
(9/88)
d/73)
(7/73)
(7/73)
Date
(9/90)
(3/83)
(5/82)
(ND)
(12/89)
(3/90)
Appendix C (continued)
Water Program (cont)
Form Title
NPDES (DMR) Laboratory Performance Evaluation
Civil Litigation Review
UIC Permit Application
Application to Transfer Permit
Injection Well Monitoring Report
Completion Form for Injection Wells
Completion Report for Brine Disposal, Hydrocarbon
Storage or Enhanced Recovery Well
Annual Disposal/Injection Well Monitoring Report
Well Rework Record
Plugging and Abandonment Plan
Notification for USTs
NPDES Application for Permit to Discharge-Short Form A
NPDES Application for Permit to Discharge-Standard Form
A-Municipal
NPDES Application for Permit to Discharge Wastewater-
Standard Form C
Toxics Program
Form Title
Chemical Substance Inventory Report
TSCA Investigation Summary
Manufacturer's Report Preliminary Assessment Information
Comprehensive Assessment Information Rule-Reporting
Form
Notification of PCB Activity
Mercury Reporting
C-2
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Appendix C (continued)
Form#
3510-3A
3510-3B
Date
(5/80)
(5/80)
8700-12
8700-12B
8700- 13A
8700-22
8700-22A
(6/85)
(2/80)
(5/80)
(9/88)
(9/88)
Fortn#
3520-2
3520-3
3520-7
Date
(5/85)
(5/76)
(9/87)
Form#
3540-2
3540-5
3540-8
3540-8A
3540-16
3540-20
3540-22
Date
(3/77)
(5/76)
(11/88)
(11/88)
(10/81)
(4/75)
(4/75)
Solid Waste Program
Form Titlg
Acknowledgement of Application for a Hazardous Waste
Permit
Acknowledgement of Application for a Hazardous Waste
Permit (Verification)
Notification of Hazardous Waste Activity
Acknowledgement of Notification of Hazardous Waste
Activity
Generator's Annual Report
Uniform Hazardous Waste Manifest
Uniform Hazardous Waste Manifest (Continuation Sheet)
Air Program
Form Title
Lead Additive Report for Refinery
Lead Additive Report for Manufacturing Facility or Site
Notice of Violation of Section 211 of the Clean Air Act
Pesticides Program
Form Tide
Notice of Inspection
Report of Analysis
Application for Registration of Pesticide Producing
Establishments
Application for Registration of Pesticide Producing
Establishments
Pesticides Report for Registration of Pesticide Producing
Establishments
Use Investigation Report
Corrective Action Report
C-3
-------
3540-25
3540-26
8500-1
8580-7
(3/77)
(3y?7)
(6/83)
(3/83)
Form#
3500-5
Date
(5/90)
Appendix C (continued)
Pesticides Program
Notice of Pesticide Use/Misuse Inspection
Receipt for Pesticide Use/Misuse Samples
TSCA, FEFRA, SARA Title HI Investigation Report
F1FRA Investigation Summary
Enforcement Program
Form Title
Fuels Field Inspection
C-4
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*V*^V-V'«MV.VA%>W*%V.»%^^
Appendix D
FACILITY DEFINITION GUIDANCE FROM THE FACILITY
IDENTIFICATION DATA STANDARD
IMPLEMENTATION PLAN (FIDSIP)
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1.4.1 FACILITIES TO WHICH EPA FACILITY ID
CODES MUST BE ASSIGNED
The word "facility" represents a wide range of entities as defined by each of the
environmental media programs within EPA. Inconsistency in the definition of a "facility" among
the environmental programs poses a challenge in ensuring the uniform assignment of facility
identification codes. It is difficult to have a single, all-encompassing facility definition that
satisfies the specifications of all the programs. Therefore, the FIDS defines a facility as "...a
locational entity, deliberately established as a site for designated activities, but not primarily for
habitation (even though on-site habitation may be necessary to the execution of the primary
activities). Examples include a factory, a military base, a college, a hospital, a national park, an
office building, or a prison." * This definition, while seemingly general, allows program managers
(who help determine whether an entity should have an EPA facility ID code) to apply a
"common-sense" approach to uniquely defining a facility. This approach is taken
because, among the various environmental laws, a facility:
Might be a discrete location (e.g., with well-defined property boundaries) at
which there is environmental regulatory activity (e.g., a permit has been issued
to this location, or monitoring at this location is required)
Might be separate areas linked by a common environmental concern
(e.g., a spill spanning several properties), and might represent a "site" rather than
a single plant
Might have several geographically separate portions which are linked by
common ownership (e.g., a Federal facility with non-contiguous sections).
Exhibit 1-1 illustrates these three ways that an entity could be conceptualized as a
"facility." Program managers, in developing and implementing their FIDS implementation plans
(Chapter 4), will ultimately identify which of their regulated entities are within the scope of the
FIDS. They might apply the following conditions when deciding whether an entity of
environmental concern is a "facility":
Is the entity the most all-encompassing level, defined by commonality of
ownership or similar environmental circumstances?
1 - Appendix A, EPA Order 2180.3, 4/9/90, p. 5, Section 8(a)
2/92 LDPIG
D-l
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Exhibit 1-1
Facility Concept
LOCATION
ENVIRON-
MENTAL
CONCERN
FACILITY
OWNERSHIP
Combination of spatial extent, regulatory concern, and ownership
that characterizes a "facility".
3/92 LDPIG
D-2
-------
Do activities occur that are regulated under Federal environmental law?
Do or could those activities cause environmental concern at that location?
If an entity meets all of these considerations, whether it is regulated by EPA or a
delegated state, it is within the scope of the FIDS. One rule is always true: every facility will be
assigned only one EPA facility identification code, although a single facility may be regulated by
many programs and thus have many program IDs.
Exhibit 1-2 summarizes the guidelines for assigning EPA facility identification codes to
entities of environmental concern. Appendix B presents suggestions for what could be considered a
"facility" within each national environmental program. The sections below offer more detailed
guidelines for determining whether an entity of environmental concern is indeed a "facility."
1.4.1.1 REGULATED FACILITIES
The ultimate source identifying which "entities" are considered "facilities" is
found within the statutes of Federal environmental laws. If a facility comes under the
jurisdiction of any Federal environmental law administered by EPA, regardless of whether
that law is actually implemented by EPA, a delegated state, or a local agency, then it
must be included in FINDS and issued an EPA facility ID code. The responsibility for
implementing the many environmental programs varies, with EPA managing some
programs (Superfund, TSCA2, FIFRA^) and states managing others (RCRA4, NPDES5,
CAA^, SDWA^). This fact has implications in delegating responsibilities for assigning
EPA facility ID codes. Chapter 3 discusses responsibilities among the various
participants of facility ID code assignment in detail.
1.4.1.2 NON-REGULATED FACILITIES
In certain cases it may be appropriate to assign EPA facility ID codes to entities
that are not regulated. Such cases might include:
2 - Toxic Substances Control Act (TSCA)
3 -- Federal Insecticide, Fungicide and Rodenu'cide Act (FIFRA)
4 - Resource Conservation and Recovery Act (RCRA)
^ - National Pollutant Discharge Elimination System (NPDES) under the Clean Water Act
6-Clean Air Act (CAA)
7 -- Safe Drinking Water Act (SDWA)
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Facilities that have been exempted from environmental regulation (but
might otherwise be regulated if not for the exemption, for example, if
they were "grandfathered out" when a law was enacted8)
Facilities regulated under state environmental laws that are not regulated
by any Federal environmental laws
Facilities that are tracked because of possible environmental effects, but
are not yet regulated per se.
This last case shows the value of the "common sense approach" to assignment
of facility ID codes. A facility which is currently tracked but not regulated, or which is
regulated under state, but not Federal, law is not required to have an EPA facility ID code
under the FIDS. Tracking information on that facility by assigning an EPA facility ID
code to it before it actually attains "facility status" will ensure continuity in information
tracking about the facility should its status change. Therefore, assignment of EPA
facility ID codes to non-regulated facilities is encouraged (but not
required).
1.4.1.3 COMPLEX FACILITIES
The FIDS requires that the facility ID code be assigned to the most "all-
encompassing" interpretation of a facility^, meaning that what could be considered
subportions of a facility (such as individual point sources, non-contiguous portions, or
operable units) are not facilities themselves, but are "parts of the whole" which must be
linked by the same EPA facility ID code. In other words, EPA facility ID codes are to be
assigned to all environmentally-regulated facilities, and all subportions of a facility such
as its outfalls and waste disposal areas are to have the same EPA facility ID code as the
most all-encompassing level of what can be considered the facility10. This is particularly
relevant to:
Facilities regulated under several laws Many facilities are
regulated under several environmental laws because they have
subportions that meet the criteria for "regulated entity" under all those
laws, such under both EPCRA1! and NPDES.
° For example, there have been occurrences of this situation in the reauthorization of the Clean Air Act
* "In some cases, a facility with complex, multiple functions may have several plants or establishments
operating within its property boundaries. For these facilities, ID codes will generally be assigned to the most
comprehensive "level." FIDS, 4/9/90, Sec. 8.b., p. 6.
10-- Sub-portions have to be linked to the all-encompasing facility level in the data base so that FINDS can
recognize the facility-level data within the system.
H Emergency Planning and Community Right-to-Know Act (EPCRA)
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T)
HH
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Exhibit 1-2
Guidelines for EPA Facility ID Code Assignment
If a facility is...
Then the facility ID code is
assigned..
Composed of non-contiguous
or off-site portions
Part of a complex of different busi-
nesses or entities (e.g, an industrial
park)
Composed of sub-portions
Not regulated (e.g., tracked, exempt,
regulated only by state law)
To the facility in its entirety (each of the
non-contiguous portions has the same
facility ID code)
To all portion^ of complex, if they are linked to
each other bv a common environmental concern;
To each portion, if independent concerns
The facility in its entirety (each of the
sub-portions has the same facility
ID code)
To the facility at the discretion of the program
('e., optionally) but recommended in case of
eventual regulation
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Facilities with non-contiguous portions - Many facilities are
composed of several portions that are separated by other things (such as
roads or another property) that are not part of the facility. Each of the
non-contiguous portions of the facility will carry the same EPA facility
ID code, indicating that a relationship exists between these different
locations.
Off-site portions Occasionally, adverse environmental impacts
not within property boundaries of a facility can be directly attributable
to activities of the facility. Certain of these off-facility sites may have
cleanup activities. Or, a facility might be required to have off-site
monitoring stations. Although these off-site locations may get their
own program-specific ID codes, they all should carry the same EPA
facility ID code as the facility with which they are associated.12. This
is particularly true for RCRA ground water monitoring wells which are
stored individually, not by facility, in STORET.
//, in a particular case, there is ambiguity about the level to
which the facility ID code should be assigned (i.e., which level is the
"most comprehensive"), the decision should be based upon the
environmental circumstances of the site.^ For example:
// all the facilities within an industrial park are linked by
a common environmental concern, such as one that results in
designating the whole park as a single Superfund site, or there is
common ownership and one Form R submitted under EPCRA (Tide
III) is appropriate, then the site is assigned a single EPA
facility ID code
If the entities are unique and independent from others with
which they happen to be in close proximity (or share a location) and
have no common linkage other than location, they could be
considered separate facilities and could thus each be
assigned separate EPA facility ID codes.
Facility situations are so unique and varied that it is impossible to cover all
possible scenarios or to develop a generalized rule satisfactory for all situations. It is
therefore crucial to have professional staff involved in EPA facility ID
code assignment and a mechanism in place to resolve discrepancies.
Particularly troubling definitional cases should be brought before the Facility
Identification Advisory Task Force (FIAT) for resolution. A brief description of the FIAT
is given in Chapters 2 and 3.
1 -- Off-site portions have to be linked to the all-encompassing facility level in the data base so that FINDS can
recognize the facility-level data within the system.
"In some cases, a facility with complex, multiple functions may have several plants or establishments
operating within its property boundaries. For these facilities, ID codes will generally be assigned to the most
comprehensive 'level.' However, a complex facility with multiple establishments or operations may receive
several IDs if more than one code is appropriate." EPA Order 21803, 4/9/90, Sec. 8(a), p. 6
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1.4.2 FACILITIES THAT ALREADY HAVE "EPA ID
CODES" FROM FINDS
FINDS was already operational at the time that the FIDS was established (April, 1990).
Staff from the hazardous waste programs, both RCRA and Superfund, relied heavily upon FINDS
to assign facility identification codes for creating records in their own program data bases and
tracking other sources of data for their facilities. Therefore, identification codes had already been
assigned through FINDS to many facilities, particularly hazardous waste facilities, by April of
1990. The FINDS identification codes were 12 digits long and had either a DUNS14 number or a
GSA1-5 code embedded in them. Some of the programs needing these codes, in particular RCRA
and Office of Federal Activities, used the codes embedded in the FINDS identification codes to sort
through and select facility records, or relate those facilities to other data bases (such as Dun &
Bradstreet).
These FINDS ID codes are "grandfathered" in the FIDS and do not need to be replaced
with the new EPA facility identification codes. Facilities to which "EPA ID codes" had
been assigned prior to adoption of the FIDS do not have to have them replaced
with new EPA facility identification codes (the data element name, however,
should be changed to "EPA Facility Identification Code"). The appendix to the FIDS
clearly states that "...These codes do not have to be replaced, i.e., new standardized ID codes for
these facilities need not be assigned."^
By "grandfathering in" the IDs assigned prior to adoption of the FIDS, as well as by
assigning new IDs to new facilities according to the standard, the population of identification codes
assigned by FINDS will eventually become a mixture of old and new codes. Because of this
heterogeneity, program systems will no longer be able to rely upon embedded meaning in these
codes. This may mean developing an independence to any meaning embedded in the ID codes (such
as software that assumes that part of the ID code is a DUNS number). This aspect should be
considered in the program implementation plans (Chapter 4).
14~ Dun & Bradstreet DUNS Universal Numbering System
" General Services Administration (GSA)
16 -- Appendix to EPA Order 2180.3, 4/9/90, Sec. 4.4, pp. A-4 to A-5
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1.4.3 ENTITIES THAT ARE NOT FACILITIES
There are many entities of environmental concern that are not "facilities." These entities
are not locationally based and/or permanent Such entities include:
Places that can be locationally identified by their
latitude Ilongitude coordinates and about which data are collected,
such as ambient monitoring stations, river reaches, protected habitats, or
ecoregions, which are tracked or monitored for their environmental significance
but are not (nor ever will be) regulated
Businesses that are regulated but cannot be identified by their
"environmental" location because they are mobile, such as
transporters of wastes or water haulers
Temporary entities, such as highway spills that are quickly cleaned up, or
portable operators, that operate at a particular location (with a permit) for a short
period of time and then move to another location to operate (e.g., barges, mobile
air pollution sources)
Corporate locations that may be identifiable by their Dun & Bradstreet
numbers, but at which no activity which could cause pollution at
that location occurs, such as corporate headquarters offices or broker
locations (these companies may be permit holders for regulated activities at other
sites, and those sites would be "facilities")
Places for which permits to build have been applied, but which have not
yet been constructed.
There are, and will be, entities that do not fit existing definitions or guidelines. For
example, uncontrolled hazardous waste sites are almost all unique in their spatial, ecological and
corporate circumstances. Therefore, careful control and experienced judgement must be used in
determining whether an entity is a "facility" that requires assignment of an EPA facility ID code.
The FIAT, as introduced in Chapter 2, will act as the oversight organization for FIDS
implementation and will be responsible for determining whether an entity type is within the scope
of the FIDS. Additional responsibilities of the FIAT will be discussed in Chapter 3.
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