LOCATIONAL DATA POLICY
IMPLEMENTATION GUIDANCE

    Comments Summary
                            Printed on recycled paper

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              LOCATIONAL DATA POLICY
             IMPLEMENTATION GUIDANCE

                  Comments Summary
Prepared by BOOZ'ALLEN & HAMILTON Inc.
Contract No. 68-W9-0037
Delivery Order 094
Printed on recycled paper

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LDPG!SSUES-- COMMENTSSMMARY
RESOURCES
Types of Comments Specific Comments Commentors Resolution
Funding is needed for GPS
acquisition, training; also a
need for trained people
.For the Regions and the States to substantially
upgrade locational accuracy, funds will need to be
budgeted to purchase global positioning equipment and
training...”
“I have some concern that the funding for these
responsibilities will not be in place by the time the final
document hits the streets...”
“We have concerns about the timing for identifying GPS
as the preferred technology. The final [ LDPG] could
precede funding [ and] a procurement vehicle...”
“...Specify the responsibility of EPA Programs
implementing this policy in providing sufficient training for
state delegates and the necessary technical resources to
carry out the EPA requirements i.e GPS units, etc.”
“OIRM should provide regional contractors dedicated to
collection of [ location identification] data in support of
program offices...”
“... EPA [ may need to have access to] a set of approved
GPS professionals, perhaps similar to the asbestos
removal specialists, to which industry should refer in
obtaining data using GPS...”
GPS Primer accompanies
LDPG. Funding and
arrangements for training
(available from a number of
sources) must come from
programs; OIRM has limited
funds which may be applied
such as SEDM financial
assistance grants. Regional
GIS Work Group member
may be helpful in identifying
sources of equipment and
training in each region.
RB
R7
R7
OR
OTS
..OTs:
1/23/92 Draft page 1

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LDPG ISSUES -- COMMENTS SUMMARY
RESOU RCES (continued)
Types of Comments
Specific Comments
Commentors
Resolution
FINDS enhancements
(retooling and address
matching): resources must be
committed, identified in LDPG
.
“The FINDS system needs increased funding so as to
upgrade the locational accuracy components of that critical
data base.”
“ [ FINDS management is not in the process of populating
at/long data elements in FINDS facility records]
until.. .funding issues [ are resolved]...”
R8
OIRM/PSD
Clarified Sec 5.1.8 (Role of
FINDS) to indicate that
OIRM is working to populate
lat/lorigs in FINDS
Ability of EMSL-LV to
support everyone’s need
for technological support
for GPS, and source of
resouráes: needs to be
developed
:
•
“Throughout the [ draft LDPG) there is.. .reference made
to the role of EMSL-LV. ..The incorporation of a GPS
research and tech support mission is a natural evolution
to our current GIS mission...However, without the
identification of necessary funding to support a GPS
program we will be constrained in our efforts to fulfill our
ro le. ’
“There is a considerable commitment for Las Vegas to
support this policy. Will resources be provided by OIRM
orORD?”
EMSL-LV
EMSLLV
Revised role of EMSL-LV as
primarily research in Sec.
4.3.1 .1.
FundIng.:will.be.neéded for
• systern.reconflguration
.


“...Because of [ having to meet other requirements...we may]
not have the resources for reconfiguring existing data
bases, especially along the line described in Chapter 5 of
the LDP Guidance.’
MN
•
.

Amount, source of funding
for system reconfiguration,
and impact on states to be
addressed in Program
Implementation Plans. Use
of SEDM grants also a
possibility.
LATF discussion of some
incentives is inappropriate for
widespread dislribt thon,
caveats must precede them
or they shoutd be deleted
from LDPG
Revise the financial incentive sections on pages 3-5,
A-25, and A-26 (Chapter 3 and Appendix A) There are
several incentives which are not [ necessary] for a widely
distributed document”
Assoc
Comptrofler
Shortened discussion of
financial incentives in
Chapter 3, said need for
data is a powerful incentive
and partnership is
encouraged left appendix,
summarizing LATF intact
1/23/92 Draft page 2

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LDPG ISSUES -- COMMENTS SUMMARY
RESOURCES (continued)
Types of Comments
Specific Comments
Commentors
Resolution
SEDM grants made
available for LDPG
implementation by states
will decrease the
availability of those grant
monies for other uses
“Incentives for locahorial accuracy seem to target
SEDM Grants in many forms (See section A 24).
While this is not for a bad cause, t does take away from
other SEDM objectives such as basic communications.”
OIRM/SEDM
Revised responsibility
section describing
IMSD/SEDM role to show
SEDM as facilitator of and
not sole motivator for states,
and that support should
come from programs and
states, as well as SEDM.
Procurement vehicle
for GPS needs to be
put in place, identified
for users
“The procurement of multiple GPS units will require an
agency procurement contract. Equipment specifications,
procurement negotiations and vendor bids should begin
immediately to permit regional end-of-year purchases.”
“GPS is the preferred technology but... we (EPA) do not
have a GPS procurement in place.’
“The guidance needs to state which office(s) is responsible
for obtaining a vehicle for use of this technology (GPS) to
obtain lat/long(s).”
R9
R7
OWEP
Explained that support
may be available from
within in each region.
Programs requests OIRM
funding for FY 92 or FY 93
cycle to implement the LDPG
•

“We request that OIRM provide... FY’92.. .funding
[ approximately $200K of additional FY 92 funds] as needed
to support the LDP requirements. If for some reason OIRM
funding assistance for FY ‘92 is not available, we would
plan to request FY ‘93 funds through the normal budget
schedule.”
..“The [ LDPG implies that the] burden of reporting (at least
in part) [ is upon] EPA or [ the] state [ and not oni the
regulated entity which has historically provided most of the
locational data during reporting.. .OIRM and OPPE should
seek. ..funding in FY93-96 budgets. ..There should be
incentives for compliance by the regulated community [ in
addition to EPA and states)...”
OAQPS
OTS
OIRM plans to use a limited
amount of FY92-3 funds
toward assisting in LDP
implementation.
1/23/92 Draft page 3

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LDPG ISSUES -- COMMENTS SUM ; .
STATE ROLE
Types of Comments
Specific Comments
Commentors
Resolution
Current state practices for
collecting/documenting
location identification data
may need revision to comply
with the LOP
.
‘Most states work in UTM or state plane coordinate
systems... The states are not going to change this practice
because of the LDP. This will be viewed as an additional
burden. [ However), GCTP has been implemented within
ARC/INFO allowing conversion between coordinate
systems.. .They (states) [ mayJ only convert.. to comply with
EPA mandates.”
EMSL-LV
The roles and
responsibilities of states
under the LOP will be
defined in individual program
LDP implementation plans,
maybe on a state-by-state
basis if necessary.
Explanation of available
conversion software was
expanded as to be of
possible value to states.
Have a more comprehensive
section on state responsibility
“The one half page under State Delegates is at best,
cursory, in addressing [ the ability of states to carry out
implementation of the LDPJ. Although issues are
considered throughout the document, it seems that specific
considerations as to EPA/State expectations should appear
here.”
OR
Substantially enhanced state
responsibility section.
State comments should be
solicited on LDPG
..
“For future drafts, you might consider allowing sufficient
lead time for us to obtain the states’ views on this
implementation guidance.”
R9
Regions are invited to
circulate LDPG to states.
Strengthen media program
office responsibility to motivate
states (including providing
resources), with OIRM/IMSD ’s
Information Sharing Branch
(ISB) as facUitator, networker,
not instioator
Emphasize importance of
State cooperation.
“There should be some specific language regarding the
EPA Programs responsibility in implementing this policy
as it relates to the States.”
“.. . Program Offices have primary responsibility for
assuring State compliance, not ISB (the SEDM program
manaaersl. SEDM is a facilitator/networker coordinator,.,”
“...70% of EPA data is gathered by states...”
OR
01 AM/SEOM

OIRM/PSD/GIS
Clarified responsibilities of
SEDM, media programs and
states as recommended.
Augmented importance of
state buy-in (Sec. 4.4, “State
Delegates”) as well as Sec.
4.3.2 (that media programs
must ensure their delegated
states comply).
.
.::
1/23/92 Draft page 4

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LDPG ISSUES -- COMMENTS SUMMARY
SCHEDULE
Types of Comments
Specific Comments
Commentors
Resolution
Shorten time for system
redesign and retooling
“Many regional media programs will begin collecting
locational data as soon as the GPS technology is
available. The planned timing for ‘System Redesign’ and
‘Tooling’ could possibly be shortened to accommodate
this new data.”
r 9
Time flexibility is necessary
for complexity of system
redesign efforts. No change
made to original schedule.
Give states more time to
convert existing data
“.. . It is important that EPA allows a degree of flexibility in
the adoption of the locational data policy. In particular,
the schedule for converting and replacing locational data
seems ambitious.”
MN
Waivers to schedule can be
addressed in each Program
LDP Implementation Plan. Re-
worded Sec. 6.1 opening para-
graph to clarify expectations.
Plan for replacement of
location identification data
that already exists t
approach 25m accuracy goal
(P. 2 3)
“...Replace locational data during future site visits for those
entities that are visited regularly. A schedule for compliance
could be imposed for only those entities that are not regularly
viSited.* *
“...lnitial emphasis should focus on computerizing data EPA
has already collected or required the regulated community to
collect, and verify its accuracy... This will provide a set of
targeted facilities for improvement. In most cases, these
“historical” facilities...provide the most information for
cross-media spatial analyses
MN
OTS
.
Section deines
incremental data collection
Guidance to Selecting
Latitude/Longitude Collection
Methods) to use various
routine opportunities to
collect/improve data (also
referred to in Sec. 2.1.3
footnote).
Define schedule for
repladng “old data with
newN
•
.
••••••••••.••••••
“...What is to be the policy for waivers regarding regularly
updated sets of data...? Should we assume that in some
near-term future year, all these entities should be
counted as “new” and subsequent reports will be
considered “old?”
OTS
•.
•
••••••• •..
The Agency goal is to have all
existing location identification
data have better than 25m
accuracy by 1995. The
replacement of existing
locational data (either
centrally or incrementally) will
depend on each program’s
internal schedule for replacing
data, and must be defined in
their implementation plans.
1/23/92 Draft page 5
* May be Interpreting LDPG to say that all locational data must be replaced by data with better than 25 meter accuracy

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LDPG ISSUES --COMMENTS
SCHEDULE (continued)
SUMMARY
Types of Comments
Specific Comments
Commentors
Resolution
Schedule conversion to GPS
so that it doesn’t precede
available money, training, etc.
“The MPCA encourages EPA to develop and implement
technical support to provide equipment and training in GPS
applications and we suggest EPA provide this support before
requiring states to commit to the GPS technology.”
“The final document could precede funding, a procurement
vehicle, identification of Quality Assurance/Quality Control
methods, compatibility between vendors, or having a working
GPS in any of the regions.”
MN
R7
No change to original
guidance; GPS use will be a
phased effort with plans
developed first in order to
set an agenda for use of
GPS; must start with
whatever resources are
available
Explain why 6/92 was
chosen for GIS.
Coórdiflate doôument date of
Program: lmptemerttàtion
Plans (10/91) wIth release of
“Explain why June 1992 was selected as the date for the
Agency moving to widespread use of GPS for collecting
new tat/longs.”
“...Why the June 92 refference] earlier (opening of Oh. 3 vs.
Sec. 2.2.4, paragraph 1)?”
“The.. .guidance for use of . ..GPS technology will not be
available until December 1991. This [ guidance] should be
available to program offices to complete the
implementation plans which are due by the end of FY
[ 911. The time frame for completion of these two events
should be re-examined.”
::.: €. d frnO to dô.
Program Implementation “ End of FY 1991 may be ambittous”
EMSL-LV
01 RM/PSD/GIS
The LATF recommended
that the transition to 25m
accuracy and wide-scale use
of GPS begin in 1992, when
all the necessary satellites
are in orbit, and that the
transition be completed, and
full implementation be
started in 1995. Expanded
explanation in Sec. 2.2.4 to
describe the planned full
deployment of satellites.
GPS Primer completed and
accompanies LDPG. Due
dates for Program LOP
Implementation Plans
revised (see below).
Dates were realigned with
presumed beginning in 1992,
required completion by
December 1993.
1/23/92 Draft page 6

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LDPG ISSUES -- COMMENTS SUMMARY
SCHEDULE (continued)
Types of Comments Specific Comments Commentors Resolution
Realign dates to reflect
current circumstances
(See Exhibit 5-1 for necessary date changes); for example:
move FINDS decision from March 91 to September 91;
change completion of geocoding methods analysis from
March 91 to November 91; change final LDP
implementation guidance from March 91 to November 91;
Completion of IRM Steering Committee Review of program
plans from March 92 to August 92; change completion of
data collection for Priority I systems from September 92 to
September 93; change completion of data collection for
Priority II systems from November 93 to July 94; change
completion of data collection for Priority Ill systems from
March 95 to September 95. (Also referring to Sec. 6.2)
O IAM/PSO/GIS
Realigned dates as
necessary (but not exactly as
suggested in comment). For
example:
• Add-mat to FINDS from
3/91 to 6/92
• Completion o f Guidance
to Selecting
Latitude/Longitude
Collection Methods from
3/91 to 12/91
• Final LDPG from 3/91 to
1/92
• IRM Steering Committee
review of Program LDP
ImpI. Plans from 3/92 to
9/92
• Data in Priority Ill systems
from 3/95 to 12/95
Also, removed Geocoding
Study (Appendix D) because
its successor, the Guidance
to Selecting Latitude/
Longitude Collection
Methods, accompanies this
LDPG.
1/23/92 Draft page 7

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LDPG ISSUES -- COMMENTS
MISCELLANEOUS
Types of Comments
Specific Comments
Com.mentors
Resolution
User documentation could
cover method, description
instead of recording them in
program data bases
“If the coordinates were obtained using the same method, a
statement in the documentation under the latitude/longitude
data elements should suffice, thus eliminating resources for
modification of the data base, data entry, and data storage.”
OWEP
Documentation not likely to be
readily available to everyone
accessing a data base.
Guidance remains unchanged.
25 meter accuracy goal will
require change to regulations
in some cases
.
“Until the regulations and corresponding permit applications
are changed, data collected for new industrial facilities will
still be greater than 25 meters.”
OWEP
Regulatory constraints should
be addressed in program LOP
implementation plans, waiver
requests (Sec. 6.1.10).
EMAP seems to be. singled
out for LOPG adherence
“...EMAP must implement the LDP -- SO does every other
program in EPA. Why single out EMAP for special
mention?” (Sec. 4.3.1.1)
EMSL ’LV
,
E-MAP was not singled out,
but merely referred to as a
key data collection (same is
true for STORET for OW).
,
Have LDPG reviewed by
other state agents of Federal
environmental laws (e.g.,
Depts,. of Agriculture,
Health)
“...Invite comments from other Minnesota state agencies
that will be directly affected by this policy [ e.g., MN Dept. of
Health; MN Dept. of Agriculturej...These agencies have
responsibilities for managing or creating EPA-funded data
systems, either as direct recipients of EPA funds or as
pass-through recipients from grants award by the MPCA.”
MN
Regions may invite any
appropriate state agency to
review LDPG.
FICCDC•is asof 10/90 (circ.
A .16)FederalGeographic
Data Committee:(FGDC) -
EPAis..chàrter Steering .
Committee member
“...recently renamed the FGDC
“Hasn’t the FICCDC changed its name?”
(Revise Secs 5 2 2 and 5 2 3 to reflect current structures of
FGDC_and_FGCC_and_EPA’s_relationship to_them)
OIRM/SEDM
. .
EMSL-LV.
.
QIRM/P$D/Gl$
Changed all references from
FICCDC to FGDC and/or
FGCC as appropriate.
The LOP does not require
automation of method,
description and should be
so stated fn the LDPG
“The [ LDP] does not require automation of method and
description The guidance should make this clear and
describe how to handle these elements in user
documentation ‘
OWEP
The LDP does not require
automation of any kind (p 8-1,
paragraph 1), complete
locational information in data
bases will increase the utility of
those data bases to secondary
users No change made
1/23/92 Draft page 8

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Types of Comments
Specific Comments
Commentors
Resolution
OIRM should provide
acquisition .vehides for all the
software mentioned in
Chapter 7
“OIRM needs to obtain a vehicle if one does not exist to
provide support to program off ice [ s] who wish to use these
methods [ such as address matching services].”
OWEP
Datum conversion software
is available to all programs
from ORD. Responsibility for
conversion software (e.g.,
address matching) given to
QIRM (GIS program).
Policy format for Iat/lor g “The format for representing at/longs has spaces in it. This EMSL-LV
differs between guidance is inconsistent with our standard for reporting, isn’t it?”
and LOP

“It is expected that an agency Information Resource OIRM/ASD
Directory System, also known as a repository, will have
capabilities to facilitate documentation, implementation and
enforcement of standards such as the LDP.”
.
Policy was written for clarity.
Format in implementation
guidance is the one to be.
adopted (Sec. 2.2.1 and
2.2.2).
Not currently appropriate
(IRDS for administrative
data) but could be
reconsidered at some future
point.
“NPDES/DMR laboratory Performance
Evaluation is a
form used to evaluate laboratories and
facilities. This form should be deleted f
not regulated
rom the list.”
“... It is very important that the ‘description field’ be
dissected further to capture certain data elements such
as ‘date’ in a ti format This will enable queries to
be performed..
Reference to this form in
Appendix C (p. C-2)
changed based on
comment.
No change (Secs. 2.2.5,
8.1.2.3). Impossible to
itemize every distinct type of
entity to be described,
maintain the list, ensure QA,
1/23/92 Draft page 9

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LDPG ISSUES -- COMMENTS SUMMARY
M ISCELLANEOUS (continued)
Types of Comments Specific Comments Commentors Resolution
Regional SEDM coordinators
can not !‘support data
coHectlonH and “assure” LDP
adherence
“ [ Providing support for aU data collection activities involving
the states] is an impossible task for [ regional SEDM
coordinators] and may be beyond SEDM...”
“.. .The role to [ “oversee compliance”] is [ one] few [ regions]
are likely to embrace...”
“The accuracy ranges shown on the graph do not agree
with the ‘Observed Accuracies’ stated in Appendix D. A
person using the graph could be misled about the capability
of a procedure to achieve the 25 meter standard {sic}...”
“it the coordinates were obtained using the same
method, a statement in the documentation under the
latitude/longitude data elements should suffice.
“The form NPDES Discharge Monitoring Report should
be deleted from the list since this form is submitted on a
monthly basis and lat/long would not need to be obtained
this frequently...”
“In the case of TRI where reports are submitted annually,
why not populate the back-data with new lat /long data
based on facility ID match? Basically don’t perform data
collection for facilities that are updated annually anyway.”
OIRM/SEDM
OTS
• R7
Rephrased Sec. 4.3.1 .3
Appendix 0 is no Longer the
“geocoding study.” Instead,
the Guide to Selecting
Latitude/Longitude
Collection Methods
accompanies LDPG; the
Guide has been reconciles
t? tQi ic?accompany
every observation of at/long
because users with access to
data may not have access to
its hard-copy documentation.
No change made to
requirement.
To avoid repetition, programs
should consider pre-printed
forms for data collection once
the basic location information
is established; added as point
inSec5.1.5. Can be
addressed in LDP
implementation plan.
OWEP
1/23/92 Draft page 10

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Type.s of Comments Specific Comments Commefltors Resolution
“Throughout this document, the phrase ‘lat/long
coordinates’ is used. A more appropriate phrase would
be ‘geodetic coordinates’ defined in terms of latitude and
longitude.”
“Is there addressed anywhere the fact that new data
collections may be driven by new regulations?”
“The [ LDPG] should.. .expand its discussion of.. .the
impact of additional at/long data and. ..GPS [ use] in
reporting rules or permits... EPA [ ’s] Information Collection
Budget. ..is likely to be a critical point for many program
offices, which are already coping with a lowering
ceiling. ..Specifics are needed about the nature of
support in rule making which can be expected from
OPPE...”
“...To minimize regulatory burden and encourage
innovation, most rules specify only the goal (e.g., 25m)
and allow reporters to use whatever means appropriate
to achieve this...”
“The distance between units of latitude are not ‘always the
same’ since the earth is ellipsoid, even though it can be
considered so for most practical purposes.”
EMSL-LV
OSWER/LATF
OTS
Corrected reference
(Sec. 4.3.1.1)
Regulatory constraints
should be addressed in
waiver requests (Sec. 3.3.3).
No change made to
reference (Sec. 2.2.3)
“EPIC is not a center of excellence, it is a component of
EMSL-LV.”
Use phrase. “geodetic.
coordiñatésdéflñed in
R7 Recommended phrase
added to Sec. 1.1.1.
1/23/92 Draft page 11

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LDPG ISSUES.- COMMENTS SUMMARY
MISCELLANEOUS (continued)
Types of Comments
Specific Comments
Commentors
Resolution
Sites visits may not be a
reliable opportunity to
collect or replace location
identification data
“If EPA or states [ are to] collect [ latilongj data, there is
an issue of the right of entry to sites.. ,EPA currently
relies on inspection authority for most visits, and does
not routinely visit sites applying for permits or submitting
forms
OTS
Not all locational data needs
to be collected by visiting
the sites. Some can be
collected by requesting
them on application forms
(such as a permit application
form) or site visit (e.g.,
inspection) forms. On-site
verification or data collection
can be performed as the
opportunities arise
(“incrementally”). Sec. 6.1 .2
reworded to address need to
get site-entry permission.
LDP implementation is
best accomplished on a
program-by-program
basis
“.. .The requirement to coordinate by law instead of
program office (p. 6-1) is unduly burdensome...in...cases
where portions of a law are administered by several
offices...”
OTS
The intent of the reference
on p. 6-1 was that
implementation is to be
accomplished on a
by-program, not by-law,
basis. Environmental
initiatives, which may not
have a law, were added.
Strengthendiscussion.on
relevancy of rev sed
pobey

“...The distinctions between the original policy, which
requires collection/documentation of locational data,
method, and accuracy for all entities and the revised
policy which recommends GPS a 25m goal, etc ,must
be emphasized better One plausible reading of the
document is that the waiver process applies to all
aspects of the policy, or of the need to collect locational
data at all
01$
Upon revision of the policy,
the intent of the waiver
process was also changed
so that waivers can apply to
any aspect of the policy not
just use of GPS or achieving
the 25m accuracy goal.
1/23/92 Draft page 12

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LDPG ISSUES -- COMMENTS SUMMARY
MISCELLANEOUS (continued)
Types of Comments
Specific Comments
Commentors
Resolution
Documentation of date
“.Date is required in the datum write-up.” (Sec. 2.2.1 .3
OIRM/PSDIGIS
Datum is required as part of
documentation of the method
used to measure Iatllong,
UQI date.
PoHu on prevention
should be a motivation for
LOP adoption
“...Highlight [ references to states in Sec. 1.1, and list]
poHution prevention [ in Sec. 1.1 .2 as an] Administrator
priority
O IRM!PSD/GIS
Changes were made to Sec.
1.1 .2 to refer to pollution
prevention as recommended.
Expand the degree of
Agency compliance with
the FGDC
.
“.. . [ Refer to the FGDC recommendation for] a spatial data
transfer standard for the exchange of mapping, surveying
and related spatial data using [ lat/long]
OIRM/PSD/G IS
.
•
Sec. 1 .2.2 has been revised
to include the FGDC
recommendations and clarify
the relationship of the FGDC
to the FGCC. Also added
Sec. 8.2.3 to discuss the
national Spatial Data
Transfer Standard.
1/23/92 Draft page 13

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LDPG ISSUES -- COMMENTS SUMMARY
NAD27 vs NADS3 and THREE DIMENSIONALITY
Types of Comments Specific Comments Commentors Resolution
NAD83 is now government
standard
“...The standard datum ... should be NAD83 rather than
NAD27. It is more precise, . ..identical to the datum used by
GPS, and is the datum of the future.”
“I would recommend that the use of NAD83 be initiated as
soon as possible. Philosophically it seems backward
looking to transform solid GPS data to NAD27...Using
NAD83 which adopted the meter as a unit of length also
eliminated the inherent confusion of unit of length in
NAD27 [ ,] where the U.S. foot, international foot, and meter
were used by various states.”
“It is logical for EPA to begin using NAD83 at the onset of
the LDP.”
“The USGS Topographic Instruction 89-1 -D dated 12/26/89
states that all new map products or recompiled old
products will appear in NAD83. ..At some time in the near
future, EPA will have to transition to NAD83...”
“...NAD83...”
“What datum has FGDC recommended? 27 or 83?”
“...The National Geodetic Survey is encouraging all mapping
and surveying organizations who use or produce spatial
coordinate information to transition from NAD27 to
NAD83...”
“... [ Refer to the] Federal Register [ for) NAD83 and
SDTS*, etc.” (referring to Sec 4.2.4 on authority)
* -- Spatial data transfer standard (SDTS)
R7
R7
R7
EMSL-LV
OIRM/GIS
01 RM/SEDM
01 RM/PSD/GIS
Cl RM/PSD/GIS
Changed recommendation
for NAD27 to NAD83
throughout LDPG. Also,
added 0MB Circular A-i 6 as
an “authority” in Sec. 4.2.4.
1/23/92 Draft page 14

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LDPG ISSUES -- COMMENTS SUMMARY
NAD2I vs. NAD83 and THREE DIMENSIONALITY (continued)
Types of Comments Specific Comments Commentors Resolution
Require elevation (takes
3 dimensions to establish
a point)
“All EPA data bases should include mandatory fields for
elevation (Height above sea level) with the understanding
that reporting could be waived. GPS collects the elevations
so there is little reason to discard the third dimension...’
“I would strongly recommend that all EPA data bases
include mandatory fields for elevation (height above sea
level) with the understanding that reporting is
optional.. .There are many instances where data is acquired
at the same lat/long only at different heights.
“...Note [ that] more than one sample [ can be] collected at
the same geographic coordinates and [ there may be]
difficulty in reporting the data item without an elevation data
item data base field.’
No change. Elevation is not
necessary to all data
applications and is an
additional burden which may
not be achievable. The
LDPG, however, clearly
does not Dreclude elevation
from being collected if the
data collectors decide to do
so. 3-Dis to be collected
when appropriate. Sec.
8.1.4 explains that latliong,
method, description, and
accuracy can be in addition
to, not instead of, other
needed location
identification data (which
includes elevation).
R7
R7
R7
1/23/92 Draft page 15

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LDPG ISSUES COMMENTS SUMMARY
REPORT FORMAT, PRESENTATION
Types of Comments Specific Comments Commentors Resolution
“... [ The LDPGJ is a wefl written document and requires
only minor editorial changes. I wish aU of our guidance
documents could be as organized, clear and concise as
this one.”
“.. This is a high quality document. You and your
contractor staff are to be commended on the scope and
clarity of this publication...
“.1 think that you did an excellent job in putting together
this document...”
“.. [ TheJ draft [ LDPG) document.. .is very well done! I
congratulate you on tackling a very difficult subject and
covering it thoroughly...”
From EPA’s perspective this document appears to
be well prepared and reflects the findings from the
Locational Accuracy Task Force...”
“The authors of The Draft Locational Data Policy
Implementation Guidance are to be commended for an
excellent job in [ identifying] issues relating to the
Implementation of the Locational Data Policy
(LDP)...The document was very well written and [ wel
look forward to using the document for guidance in the
implementation of the LDP..
“,..the guidance was well-written and provides the
program office with useful information to fulfill the
directives of the Locational Data Policy.”
The LDPG was written to
anticipate all the issues that
might come up during
Agency-wide LDP
implementation. The goal
was to be comprehensive
while still leaving managers
of programs and geographic
initiatives the opportunity to
approach adoption of the
LOP in a way most sensible
to their missions.
LDPG is welI’ written
EMSL-LV
EMSL-LV
Assoc.
Comptroller
OARM
OR
R7
OW/OW E P
1/23/92 Draft page 16

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LDPG ISSUES -- COMMENTS SUMMARY
REPORT FORMAT, PRESENTATION (conttnued)
Types of Comments
Specific Comments
Commentors
Resolution
The LOP is a worth-while
endeavor
“... [ OAQPS] .tota y agrees with the draft of the
[ Locational Data Policy] Implementation Guidance
‘.. The Draft [ LDP implementation] guidance represents
the culmination of a very substantial effort. I concur
with its implementation...”
“The MPCA supports the establishment of standards for
generating and documenting location data and EPA’s
efforts to encourage the collection of accurate locational
coordinates along with other data. We feel that, if
geographic information systems are to become feasible
at the state and national level, such procedures are
essential. ..Your guidance is. ..particularly timely in
Minnesota...”
OAQPS
OIRM/ASD
MN
Full-scale adoption of the
LDP will increase the value
of all environmental data
collections for primary and
secondary users.
Commendable
achievement of
addressing technical and
programmatic issues


“The document fairly represents the difficult task of
combining information or data objectives with program
objectives and then having to address the technical
issues and resource issues
“The February 1991 draft of the [ LDPG] clearly
addresses the complex issues associated with the 25
meter accuracy standard, and the Global Positioning
Systems as the collection technology to attain the
standard The implementation appears to be firmly
based on technical feasibility and the need for GIS
analysis/display techniques to spatially integrate
information for “total” environment decision-making...”
OSWER
•
7
Full-scale adoption of the
LOP will increase the value
of all environmental data
collections for primary and
secondary users.
1/23/92 Draft page 17

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LDPG ISSUES -- COMMENTS SUMMARY
REPORT FORMAT, PRESENTATION (continued)
Types of Comments
Specific Comments
Commentors
Resolution
Use larger type
“The print size should be enlarged. The current size is hard
to read.”
OWEP
No change. Trying to keep
already lengthy document to
as_few_pages_as_possible.
Correct phone numbers
“My correct phone number is (702) 798-2377. Also under
ORD/EMSL-LV add Terry Slonecker as a secondary contact
at (703) 349 8970
EMSL-LV, EPIC
All telephone numbers for
contacts in Appendix B were
updated for 1/14/92 draft
.case study removal...”
“Chapter 9 Case Studies -- to be removed?”
“...Omit [ case studies from the LDPG]...”
“The format of the Guidance should be changed. It’s
important to state WHAT the policy is, in layperson’s terms.
Included with that topic is the reason WHY for the policy.
Use a few TOM concepts such as customer, supplier, and
user...”
“Chapter 3 - Should be an Appendix”
“If these are the true timing requirements, they should be
placed up front in summary at least, along with the required
approach and products.”
“State should be consistently capitalized.”
0 RM/GIS
01 RM/SEDM
01 RM/PSD/GIS
Case study chapter
(originally “Chapter 9”) was
removed from LDPG.
Selected format based on
analysis and categoriz-
ation of Green Border
comments and LATF
outcome No change made
to format.
Chapter 3 is a translation of
the LATF outcome into
Agency-wide guidance;
Appendix A is actual LATE
recommendations. No
change made.
Already summarized in front
of chapter in Exhibit 5-1 (p.
5-2). No change made.
State is capitalized when it is
a name, and not capitalized
when it is a noun or an
adjective.
Remove Case Studies
OSWER/LATF
1/23/92 Draft page 18

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Use correct terminology for
Community Right•to Know
Act
The more correct term for SARA Title Ill is the Emergency
Planning and Community Right-to-Know Act, or EPCRA.”
OTS
Changed all references from
SARA Title I/Ito EPCRA.
Choicel of print style should
be different
.
.
“...The line spacing seems too wide... 11 on 14 often works
well..”
The use of bold and italic is excessive [ Confine] the use
of bold to headings and titles or keywords/phrases in bullet
points
OTS
OTS
.

Bold and italicswere used
to highlight key points not to
be missed Although the use
of bold and italics was
reduced, no change made to
basic report format in this
context.
Avoid using brand names
•

“..4The paragraph reading ‘...private vendors, such as
Roadnet ETAK CDT and Dun and Bradstreet in Sec
7.1.1.1] could be seen as an endorsement. ”
OIRM/PSDIG IS.
•
Removed (or minimized the
use of) brand names from
Sec. 7.2.1.1 (formerly
7.1.1.1) and other
references
Correct terminology when
ref erring to data within
the LOP scope
.
.
[ Change locationally based’ in Sec 2 11 to
geographically based when referring to the applicability of
data]
01 RM/PSD/G IS
The phrase “geographically-.
based is more
comprehensive than our
point here the data we are
referring to are about a
place, and are therefore
locational not geographical
No change made to Sec
2 11_or_Sec_2_111
Correct secttor reference
[ Section 3 1 3 as referred to in Sec 2 11 2 does not
exist] “
OIRM/PSDIGIS
Changed reference to say
“Chapter 7”
Add a bibhography with
appropriate references
This document will require a bibliography [ including] FIPS
and FGDC [ references] ‘
OIRM/PSDJGIS
Secs 1 2 2 and 42 4 refer
to Federal inter-agency
groups and their
documentation No separate
bibliography_was_created
-- COMMENTS SL
Types of Comments Specific Comments Commentors Resolution
1/23/92 Draft page 19

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LDPG ISSUES -- COMMENTS SUMMARY
TECHNIQUE, TECHNOLOGY
Types of Comments
Specific Comments
Commentors
Resolution
Emphasis on GPS overstated,
resulting in dependence on it
.
“.. in light of the rapid schedule for converting and replacing
non-Geo-Positioning System (GPS) coordinate data with
GPS-generated coordinates and the stated expectation for
“widespread” use of GPS for collecting new latitude and
longitude data “by 1992,” the draft LDP Implementation
Guidance does not appear to reflect the cautions of the
LATF (appendix A) against “total dependence upon GPS
technology.”
.
...That this policy will evolve in accord with improvement of
measurement techniques, with advances in the information
engineering discipline, and with advances in information
technology.”
MN
OIRMIASD
GPS is presented in Ch. 3
as the current best
technology, but method will
be continuously re-evaluated
to see if OPS is still the
only/best method option.
Sec.3.3.2 begins with “...the
LATF recommendation is to
have the best available
technology applied to the
collection of locational data.
Have Tech-Transfer ufairs,u
workshop for LDP plan
deve(o ers
.
.
.
“We suggest EPA organize a series of GPS technology
fairs in which states, EPA staff and vendors of GPS
technology can share ideas and learn what is available and
what is needed.”
.
I suggest a workshop with your suppliers, the ones that
have to write the plans.. .Have a session with them which
would be partly educational and partly participative so you
could hear from them how the guidance document could be
improved.
“I What is ‘LDP awareness training’ referred to in Sec
4.2.3]?”
MN
QSWER

O IRM/P$D/Gt$
.
OIRM will conduct
implementation workshops;
reference to “awareness
training” rephrased in Sec.
4.2.3. to say “workshops.”
Also added Secs. 4.3.1 .5
and 4 3 1 6 to describe the
role that the Re ional GIS
and GPS Work Groups can
play in technology and
expertise transfer
1/23/92 Draft page 20

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Emphasize the need for
specially trained staff
LDPG ISSUES -- COMMENTS SUMMARY
TECHNIQUE, TECHNOLOGY (continued)
Types of Comments Specific Comments Commentors Resolution
R7 (2 times)
“In the GPS [ description] (Chapter 1), consider:
‘Requires a technician trained to use a GPS receiver and
a technician trained to differentially post-process receiver
data.’ The expertise required to attain the coordinates
with GPS should be reiterated throughout the document”
• .It is important to reiterate throughout the document the
expertise required to attain geographical coordinates with
GPS. .. Exhibit 7-3, .. .the expertise row of the GPS
column, . ..may better be expressed as “requires
technician who knows how to use a GPS receiver and a
technician who knows how to differentially post-process
receiver data.’
Need for trained
personnel emphasized in
GPS description (Sec.
7.3.5)
Explain how code list is to
be maintained, expanded
“The Method code list for determination of at/long is
not all inclusive. A procedure to add more codes is
needed.”
R7
Maintenance of list of
codes currently within
OIRM/IMSD, but will be
transferred to appropriate
group, either National
GIS program in PSD, or
Regional GIS Work
Group.
Reference forthcoming
“Guide to Selecting
Latitude/Longitude
Collection Methodf
“O lRMis working on... ‘Guide to Selecting Lat/Long
Collection Methods’
“Assuming [ GPS] is the technology used in the
collection process, the forthcoming ‘Guide to Selecting
Lat/Long Collection Methods’ leaves room for each
program to determine what is feasible for them to
accomplish.”
“... [ Include the final report of the geocoding study as a
compendium to this document]
OIRM/GIS
OIRM/SEDM
O IRMIPSD/GIS
The Guide is referred to
throughout the 1/1 4/92
draft of LDPG for process
to select a method,
process to estimate
costs, and information on
several geocoding
methods. The Guide
also is to accompany the
LDPG (with the GPS
Primer).
1/23/92 Draft page 21

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cOMMENTS SUMM RY
TECHNiQUE, TECHNOLOGY (continued)
Types of Comments
Specific Comments
Commentors
Resolution
Require DQO development
“mentions DQOs, which should be the bases {sic} for
OSWER
The DQO process is
instead of recommending it
determining how accurate the data should be.. . [ Programs
valuable for identifying
should] be required to use the DQO concepts, principles,
and approach in the LDP implementation plans
“ [ Development of DQOs for planning and waiver requests]
should head the list of media program office
responsibilities...”
“OIRM and ORD should develop specific DQO guidance
[ regarding locational identification data] for program
offices.. .Such guidance must be available well before
completion of program implementation plans [ and should
address potential secondary as well as primary use]
“... [ Add DQO development as part of the method
determination process]...
OIRM/SEDM
OTS
0 1 RM/PSD/G Is
the level of accuracy
necessary and selecting a
lat/long measurement
method appropriate for that
level of accuracy.
Performing the DQO process
to determine needed
accuracy for lat/long is
entirely at the discretion of
the data collector (but should
be done for waiver requests).
However, it is valuable to
recommend DQO
development also be part of
the method selection
process (Sec. 7.3.7).
Chapter 6 opens with a
.
detailed discussion of DQOs.
Also, the Guide to Selecting
Latitude/Longitude Collection
Methods presents a process
for method selection that is
.
heavily reliant on DQOs.
I Is difhcult
automa ca#y verH y
whether accurac ’ goal j
“There are currently no automated QA checks which can
detect errors at the accuracy goal of 25m OIRM
should study [ a combination of approaches, e g edit
015
The LDPG does not
address to the level of
detail of edit check options
beIng met
check to see if lat/long is in appropriate city and ZIP
code] as a follow-on to the geocoding study, and
provide data and code to major EPA systems “
PSD may be a source of
information on available
edit check software
1/23/92 Draft page 22

-------
Types ofComments
Specific Comments
Commentors
Resolution
Conversion methods are not
really “methods” -- they are
secondary methods for
converting data already
obtained
“The codes SPCSCOt’4V, TSRCONV, UTMCONV are not
really descriptions of methods. These codes refer to
conversions from other coordinates systems and don’t teH
about the original survey method.”
EMSL-LV
Added a discussion to Sec.
7.2 to explain the difference
between a collection and a
conversion method.
Identify source of project
planning software to produce
Program Implementation
Plans, as recommended in
LDPG
“The document suggests the use of project planning
software to develop Program Implementation Plans. O1RM
should provide a contact and make available this software
to offices who do not currently have access to it.”
OWEP
OIRM is developing an
approach, called a
“template,” for development of
program plans, introduced in
Sec. 4.2.2 and Sec. 6.2.1, so
reference to project planning
software in what was Sec.
6.2.1 of the 2/1/91 draftwas
deleted.
Document is unclear as to
what recommendations are
for”method° why promote
GPS and describe all those
other methods?
.
“LATF recommends GPS usage. This document flip-flops
between stressing GPS as what must be used and other
options based on each program’s DQO’s (7.2.7)
* -- Now Sec. 7.3.7
OIRM/SEDM
•

The method used should be
the best available technology.
In Ch. 3, explained the
difference between the intent
of the policy and the
endorsement by LATF of GPS
as a data collection method;
and that GPS is currently
considered the best
implementation approach, but
preferred method may
change with progress and
new technology
Dátá hversióñchákè
needs more guidance
,.
“EAdd] the factor of another conversion factor as follows:
‘FILE structure -- Is the file an ARC/INFO coverage or
ASCII file? NADCON may be used for ASCII files;
CDATUM may be used for ARC/INFO coverages “
EMSL-LV•••..

•
Expanded Sec. 7.2.3 to have
2 options: NADCON and
CDATUM. Added Sec.
7.2.3.2, modified Exh. 7-2.
1/23/92 Draft page 23

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Types of Comments
Specific Comments
Commentors
Resolution
Need guidance on how to
define location of entities that
can also be hydrologically
sited
“...For river reaches where discharges are what is sought
for record, data should approximate the pipes and not the
facility boundary adjacent to the river...”
OIRM/SEDM
Intent of LDPG is that
locational data represents
whatever the attribute data
represents; so if attribute
data is of effluent from a
pipe, location identification
data should be of the pipe,
not the receiving stream
reach. No change made.
Unclear how to coordinate
lat/lóng.data with hydrologic
identificàtioh data
..
“. . . For stream segments, it would probably be more
accurate and less burdensome to collect the extremes of
the segment, with reference to the RF3 segment number
than attempt to collect newly digitized data along the entire
segment
OTS

Removed reference to reach
file on p. 2-8 of 2/1/91 LDPG
because intent isflQtto
redigitize RF3.
Address-matching only ..
provides an.approx.irnatiofl
“Guidance must stress that address-matching provides only
an estimate of given address through interpolation along a
Street segment.”
.
EMSL-LV
Included in Sec. 7.2.1 .1
discussion
NADCON does not work In
ARC/INFO envronment

.
1. .. .::.:...
‘NADCON limitation does not work in ARC/INFO I would
recommend another column for CDATUM which works in
an ARC/INFO environment.. .EMSL-LV has implemented
NADCON (...the approved software for converting between
datums) in a GIS environment in a program called
CDATUM CDATUM allows conversion of ARC/INFO
coverages while NADCON works only in ASCII format.
EMSL LV
•. . .. : . . :..
Included in Sec 7 23
discussion
Requiring GPS will minimize
expenses of tocattonal data
collection
:.
“ [ The statement that the ‘number of different types of
equipment that must be purchased and the training that
must be given’ can be minimized by Agency-wide use of
GPS is] wrong (Referring to second bullet under Sec
3 3 2)
OIRMIPSD/GIS
• .:.. .:. :: .• . .
Limiting the different types of
equipment that can be used
probably wi//reduce the
variability in equipment used
and training necessary No
change made.
LDPG
--COMMENTS SUMMARY
1/23/92 Draft page 24

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LDPG ISSUES -- COMMENTS SUMMARY
FACILITY DEFINITION
Types of Comments
Specific Comments
Commentors
Resolution
Facility definition needs to be
clarified
“Facility definition [ needs to be clarified in terms of] tiers for
gathering points
“We still need the definition that uniquely determines what a
“facility” is [ regardingj the Agency standard and therefore,
regarding the new FINDS.”
“The document needs a section which clearly defines a
facility and other collectable entities such as smoke stacks
and discharge pipes.”
“...Other general issues include definition of a facility (e.g.,
TSCA may define a facility differently from SWA, CAA,
etc.)...”
OIRM/GIS
OSWER
OIRM/SEDM
OTS
Added definition from
Chapter 1 of the FIDS as
Appx. D; accompanying
Guide addresses having a
particular point represent
whole facility. Added more
guidance to Sec. 2.4.1
(formerly Sec. 2.2.1.2).
Define “tiers” more clearly
“A section on ‘tiering of what a facility is’ should be included
or referenced. For example, Tier 1 Front door; 2 = facility
centroid; 3 = fence line; 4 = intersection closest to fence
line
“The definition of ‘tier’ is confusing and needs to be
clarified.”
“First use of ‘tier’ is confusing since it has its own meaning
with regard to this policy. This is better explained by coming
from the DQO concept.”
“.. Tiers for gathering points
“The tiering concept needs to be better defined
OIRMJSEDM
OWEP
OSWER
OIRM/GIS
OTS
No change. Locational data
are to be of whatever the
attribute data (e.g.,
monitoring data) is referring
to, and that entity (or “tier”) is
to be communicated to
secondary users by the
value in the “description”
data element.
1/23/92 Draft page 25

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LDPG ISSUES -- COMMENTS SUMMARY
FACILITY DEFINITION (continued)
Types of Comments
Specific Comments
Commentors
Resolution
Applicability of the LOP to
temporary sites needs to
be determined
“...ln Superfund, may sites are identified for a short period of
time. Only a small percentage become NPL sites, so there
is a distinction as to the need for locational data for each
kind
“...Should off-site facilities not under the control of the
submitter have information collected [ e.g TRI waste
transfer sites]?”
OSWER/CERCLA
OTS
Added guidance to Sec.
2.1 .2 that if permanent
records are kept on
temporaly places,
location identification
data should be part of
those records. There may
be many reasons why
someone may want to
identify the location of an
incident or activity that no
longer exists.
Provide guidance on facility
location determination
“... [ Following the sentence reading ‘The data collector must
(provide) the single point that is most representative of the
entire facility within the accuracy bounds that must be
adhered to and document it in the “DESCRIPTION” field*
should be a sentence reading] Guidance is provided in
OIRM document “_“ which accompanies this document.”
* -- Now in Sec 24 1 on ‘Tiering and Spatial Extent
OIRM/PSD/GIS


:
Sentence added to Sec. 2.4.1
referring to Guide to Selecting
Latitude/Longitude Collection
Methods. OIRM is developing
workshop curricula with
guidance for deciding which
point represents a facility;
specific definitions for each
entity type or circumstance will
be in the LDP implementation
plans Therefore, no such
guidance will be given in this
LDPG However, Appendix D
was changed to excerpt the
guidelines for facility
designation (NOT location)
from the FIDSIP
1/23/92 Draft page 26

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Not all data collections need
locational data accurate to
within 25 meters; distinguish
between administrative data
and scientific data
There is a distinction between the at/long for
administrative purposes in a program, and the at/long for
scientific purposes. The scientific data needed for
standards and now as part of corrective action are still on
the like to have list, since there are few resources
OSWER/RCRA
Secs 2 111 and 2 1 3
explain data and activities
under the scope of the LDP.
LOP Implementation Plans
and waiver requests will
address any need for
exceptions. No change made
to LDPG in response to this
comment.
DQOs should determine the
level of accuracy to be
achieved, and should be
responsibility of program
managers
“The LOP Implementation Plan for each of the Offices’
programs should be based on 000 concepts, so that the
level of accuracy to work toward fits the program’s goals as
well as the Agency’s goals. The DOD process should
satisfy the programs, as they go through it,so that they
know they’ve documented and justified their objectives,
deadlines, constraints, and the resulting implementation
plans...”
OSWER
Chapter 6 (LDP
ImplementatiOn Plans) begins
with a description of the value
of the 000 process (and its
role in LDP waivers), and the
Quality Assurance
Management Staff (ORD) is
listed in the contacts.
A way of verifying
accuracy needs to be
standardized
“. . .What should be the point of reference for accuracy
for an entire facility?”
OTS
The point of reference for
accuracy should be the most
visible, accessible point in a
facility, which should be
documented in the
“description” data element
(Sec. 2.4.1). That point will
yield the most precise
location identification data (a
measurement which is most
likely to be repeatable).
There may be strong
justification needed for the
25m accuracy goa l
“.. .The incremental benefits of specific levels of accuracy vs.
cost are... needed... [ in] part to justify inclusion in reporting
rules to 0MB, industry, and the public
OTS

Achievement of 25rn accuracy
is a goal, not a requirement,
and should therefore not have
0MB implications.
Types of Comments
Specific Comments
Commentors
Resolution
1/23/92 Draft page 27

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• SUMMARY
ACCURACY (continued)
Types of Comments
Specific Comments
Commentors
Reso$ution
Cóñfldénce level of
accuracy should be
“reasonable”
.
“... [ Change ‘95% confidence level’ for accuracy range to
‘reasonable’]..”
O IRM/PSD/GlS
,
Relaxing the confidence
expectation from 95%, for
which a statistical!
mathematic approach can be
developed, to a ‘reasonable’
level, could lead to data
incompatibility and
compromised quality. 95%
confidence level remains
(Sec. 2.2.4).
Use caution in interpreting
LATE findings . .
.

.
.
.
“.. [ Referring to the three bullets in Sec. 3.3.1 about why the
25 meter accuracy goal was establishedj, who did [ a review
of program requirements which determined that a target of
25 meters was consistent across programs]?”
OIRM/PSD/GIS
.
.
A presentation was made at
the LATF by OSWER, who
surveyed program needs
(refer to memo dated
1011 6/90 from the Deputy
Director of Solid Waste to
the Director of the Office of
Water Regulations and
Standards requesting a
response to questions on the
implementation of EPA’s
[ locational data) policy with
an accuracy standard).
1/23/92 Draft page 28

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LDPG ISSUES -- COMMENTS SUMMARY
FINDS
Types of Comments Specific Comments Commentors Resolution
‘iWe). .question the FINDS initiative to do address
matching. Since the push is on, in the programs, to start
collecting or correcting lat/long data based on this
requirement, what is the purpose of address matching for
those facilities? Won’t there be two values for a facility -
one updated value from the program and one new value
derived from address matching? Will the FINDS results
satisfy the accuracy requirements?”
“Prior to employing address matching in FINDS, OIRM
should canvass the program offices to see if lat/long
coordinates exist in the program information system. If so,
the lat/long(s) from the program information systems should
be used.”
.There is a very real likelihood of redundant reporting of
facility coordinates. In many cases, EPA data systems and
data management practices prevent widespread use of
lat/long coordinates already collected.. .Should encourage
full utilization of existing EPA data.”
“QIRM is the custodian, not the data gathering arm(.) This
would be a program office responsibility.” (Referring to Sec.
5.1.8.)
Population of FINDS with
facility location identification
data is OIRM’s
demonstration of adherence
to the LDP (Secs. 4.2.2 and
5.1.6). Programs may track
sub-entities at a facility and
need not measure the
lat/long coordinates for the
facility-as-a-whole if they are
not germane to the program
mission and is in accordance
with other aspects of this
guidance (e.g., the “tier” to
which the data refers).
Why address-match in FINDS
if programs have to collect
Iatllongs for facilities?
Redundant effort
OSWER
OWEP
OTS
O IRM/PSDIG 1S
1/23/92 Draft page 29

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LDPG ISSUES -- COMMENTS SUMMARY
FINDS (cont;nued)
Types of Comments
Specific Comments
Commentors
Resolution
Address-matching to add
lat/longs to FINDS will be
performed as resources
are available, or may not
be performed; FINDS
management is not
currently populating
lat/long fields
“ [ OIRM] can probably do [ FINDS address matching] in
FY92,. Within resources available, OIRM will begin the
process of populating the FINDS inventory with lat/long
‘.. [ The statement that ‘FINDS will obtain locational data
using address matching or from media data bases
through automated updates] was a recommendation and
not a given (referring to Sec. 4.2.2 on PSD
responsibilities)
“The third paragraph on page 8-6 describes that FINDS
management is in the process of populating lat/long data
elements in FINDS facility records...This is not the case
at this time. ...We are not filling [ the FINDS latilong fields
with any values], until such time as management has
decided on the funding issue
O IAM/OD
O IRM/PSD/GIS
OIRM/PSD/FINDS
Although this has not been
finalized, “latllong” will be
part of the alias file in the
FINDS redesign, enabling
FINDS to copy at/long data
from program systems.
Sentence in Sec. 4.2.2 has
been reworded and
reference to FINDS in Sec.
8.2.1 has been scaled down
(but not deleted). Sec.
5.1 .6 does explain OIRM’s
plans to address-match
FINDS facility records to
create at/longs for each
applicable facility record.
FINDS will not have more
than one lat/long
coordinate value per
facility (FINDS may not
include location
dentificaUon data.tor
ub tacinty: tlers . ’D.

.
“...The... new FINDS will contain one field per facility for
latllong, and the data elements required to fulfill the EPA
Locational Policy.”
“... I don’t remember [ the statement ‘inclusion of accurate
lat/long coordinates for sub-facility tiers such as
discharge pipes or stacks’] as a LATF recommendation;
it was [ a suggestion] but not a formal recommendation.”
OIRM/PSDIFINDS
QIRM/PSO/QIS
. . .
.
.
Same as previous.
LATF finding regarding
documentation of
sub-facility locational data
in FINDS (Sec. 3.3.5,
second bullet) was
deleted.
1/23/92 Draft page 30

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LDPG ISSUES-- COMMENTS SUMMARY
RESPONSIBILITIES
Types of Comments
Specific Comments
Commentors
Resolution
Decision should be macfe
to establish the IRM
steering Committee as
the appropriate audience
to review waiver requests
[ The procedure that the IRM Steering Committee will
evaluate any requests for waivers from the policy], was not
determined (p. -2)
“... [ Change sentence in Sec. 1.1.3 to read]...’Applications for
waivers will be made to the IRM Steering Committee who
will review the applications and make recommendations
for compliance to the policy...’”
“... [ IRM Steering Committee receipt of Program LDP
Implementation Plans will] allow for cross-program
collaboration and reduce chance of redundant effort..
(referring to Sec. 5.1 .2)
OIRM/PSD/GIS
The IRM Steering Committee
currently has the role of
reviewing LDP
Implementation Plans and
waiver requests, and
granting or denying waivers
Sec. 4.1). Its role as recipient
of waiver requests remains
unchanged (Sec. 1 .1 .3, 4.1,
and 6.1.2).
PSD has been
reorganized
“ [ Delete the identification of the ITIBI.’ (referring to Sec. 4.2
and Exhibit 5-1)
OIRM/PSD/G 1S
As PSD has been
reorganized, the entire
reference to PSD(Sec. 4.2.2)
has been revised.
GIS policy is no longer
overseen by ORb
.
‘ORD does not set GIS policy; OIRM does.”
OIRM/PSD/G1S
:
The National Mapping
Program within OIRM/PSD,
instead of ORb, currently
has the responsibility for
Agency-wide GIS policy;
revised Secs. 4.2.2 and
4.3.1.1 accordingly. Regional
G 1S Work Group (Sec.
4.3.1 .5) may eventually have
a role in oolicv development.
Attribute responsibitityfor
GPS guidance to the
Regional GIS Working
Group
“An additional reference for the implementation of GPS
technology will be the GPS sub-group under the direction of
the Regional GIS Working Group, which consists of the
Agency’s regional GIS teams, ORD, NDPD, and the HO GIS
Prociram Office staff
OIRM/PSD/GfS
•

Regional GPS Work Group
introduced in (new) Sec.
43 1 6 but official responsi-
bility not yet determined.
1/23/92 Draft page 31

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LDPG ISSUES COMMENTS SUMMARY
RESPONSiBILITIES (continued)
Types of Comments
Specific Comments
Commentors
Resolution
NDPD is not responsible
for system updates
regarding locational data

“.. .What about systems updates to place the latJlong) data
(and attributes) once they are collected?” (referring to NDPD
responsibilities as presented in Sec. 4.3.1 .4)
OIRMIPSD/GIS
System updates to
incorporate location data,
once collected, into data
bases, is the responsibility of
each program and not
NDPD. No change made to
4.3.1.4.
.
Role of lAM Steering
Committee should be
included in descrip on of
others responsibilities
“... [ AAS (etc.) and SIRMOs must see that program LDP
implementation plans are developed and submitted to the
lAM Steering Committee]
O 1RM/PSD/GIS
Reference to SIRMO
accountability to IRM
Steering Committee added
to second bullet of Sec. 4.3.3
and Exhibit 4-4.
Delete data base
managers’ responsibility
for FiNDS locational data
.
“.., [ Are data base managers responsible for coordinating
with FINDS [ for the LDP]...?” (Referring to Sec. 4.3.3)
Q 1RM/PSD/c3lS
Responsibility removed from
LDPG. This Is, however,
data base managers’
responsibility under the
Facility Identification Data
Standard.
Emphasize resource
saylngs bypro ram
collaboration
“Mention.. .program collaboration and economics.”
(Referring to Sec. 6.1.2 and 6.1.8)
O IRM/PSD/GIS
.
Changes made as
recommended (only to
Sec.6.1 .8).
1/23/92 Draft page 32

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