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RE: My summary and an appeal


This is kind of an old thread, but I wanted to respond to Rich Puchalsky's "expose" of the Coalition for Effective Environmental Information, which he contends is using "requests for EPA to make information more understandable" to prevent EPA from responding to "requests for raw data." Rich wants this to be "the major idea . . . people carry away from this session."

In a response to an earlier posting by Rich, I emphasized how different things look from different perspectives. As an active member of CEEI, I can state that Rich's characterization is wrong. In fact, in our comments on EPA's Sector Facility Indexing Project, one of our primary points was that instead of simply releasing raw compliance data, EPA was making it more "understandable" by coming up with a compliance "indicator" under which a facility was simply "noncompliant" for a calendar quarter if it had anywhere from one to an infinite # of violations of any statute in that calendar quarter. This sort of simplification does not assist anybody.

More generally, our primary agenda has been trying to get EPA to improve the quality of its databases, and to create mechanisms to enable people to obtain corrections of errors that did NOT arise from them (e.g., spurious "violations" in the SFIP). As a general rule, we do not oppose EPA releasing raw data, so long as in indicates what it was collected for, what sorts of QA/QC have been done, what its limitations are, etc. Otherwise people really don't know what uses they can validly make and what uses are bogus (e.g., ranking states by # of exceedences of water quality standards in states that have different standards, different monitoring frequencies, etc).


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