|Information Systems and the Environment | Edited by Deanna J. Richards Braden R. Allenby and W. Dale Compton|
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Public Access to Environmental Information
PATRICK D. EAGAN, LYNDA M. WIESE, and DAVID S. LIEBL
Access to relevant environmental information can help to improve the ecology of industry. Imagine geographic databases that allow cross correlation of municipal and industrial discharges in various media (air, water, land). Envision the siting of industrial facilities on the basis of environmental carrying capacity of a geographic location. Think of the capability to determine the environmental profile of common industrial products. Technically, these capabilities exist. The ecology of industry can be improved by aggregating, evaluating, and increasing access to environmental information using information technology.
Indeed, there are several reasons to step up the aggregation and dissemination of information:
Public environmental protection agency administrators and industrial environmental managers, however, face fundamental questions about the availability of and, indeed, whether the collection of various types of environmental information will contribute to better environmental decisions in the agency or business. The public administrator's concern about accessibility and perceived value may revolve around whether greater public access to aggregated environmental information will lead to improved public policy, whereas the industrial manager may question whether access to aggregated environmental information will increase the ability to control risk from a supply chain, gather life-cycle environmental information for design purposes, or allow unwanted access to competitive engineering processes.
This paper discusses the value of aggregated environmental information to Environmental Protection Agency administrators and industrial environmental managers. It also presents the challenges in providing public access to this type of information, using the case study of an environmental information system called Fact, which is being implemented by the Wisconsin Department of Natural Resources (WDNR).1
AVAILABILITY OF ENVIRONMENTAL INFORMATION
Environmental regulatory agencies are mandated to protect the environment. As part of this mandate, federal and state environmental protection agencies collect large amounts of permit discharge and ambient monitoring data to assess regional and local environmental conditions, to determine compliance, and to charge fees. Industrial entities similarly collect vast amounts of environmental information related to their operations. Companies that implement environmental management systems under the International Organization for Standardization 14001, and adopt the goals of organizations such as the Coalition of Environmentally Responsible Economies or the Global Environmental Management Initiative, collect and publicly disclose much more information than is required by regulation. Each entity--industrial or governmental--collects environmental information to meet specific needs. The information, therefore, is available, but this information alone may not be what is needed to answer a specific environmental question or issue.
VALUE OF COLLECTING ENVIRONMENTAL INFORMATION
State agencies have partnered with other stakeholders to collect, aggregate, and analyze data. The WDNR (1996) report, Acid Deposition Monitoring and Evaluation Program, demonstrates the value of collaborating and coordinating efforts to meet data needs. In the case of acid deposition, the report states:
Industrial environmental data also has proved to be especially useful for strategic planning by regulatory agencies and providers of state manufacturing assistance. For example, state agency personnel have correlated industrial emissions information from the TRI2 with manufacturing processes. The TRI requires that companies report releases of toxins to the air, land, and water. Using the emissions data correlation, decision makers then set statewide priorities for reducing emissions at the source (Liebl, 1991, 1992). Community groups have similarly used aggregated environmental information to create demographic maps with toxic emission overlays as a basis for promoting environmental justice and to stimulate citizen activism to pressure industry to reduce the use of toxins (Dorr et al., 1993).
There are industrial and regulatory agency benefits to aggregated reporting of environmental information. The development of the Integrated Toxics Reporting System (ITRS) in Wisconsin allows for the identification and correction of data errors relating to hazardous waste generated by specific companies. The ITRS reports are reviewed by companies and cross checked against internal records for verification of data accuracy. The data from the ITRS also have been used by companies to develop full facility profiles as a first step to understanding the scope of hazardous waste generation and toxic emissions. These profiles offer managers incentives and justification to reduce toxins (WDNR, 1995).
GOVERNMENT DEMAND FOR ENVIRONMENTAL INFORMATION
In addition to the needs of public agencies for specific environmental data and information, there are several forces driving state agencies and the private sector to increase public access to environmental information. These include the need for greater administrative efficiency, the increased public demand for information, and the potential for improving environmental protection.
Public agencies have been under mounting pressure to decrease costs and increase productivity in monitoring industrial environmental performance; state agencies collect information (some of which is publicly available) from companies. This information is used to fulfill requests for paper copies of reports and permits or to provide notices of violations relating to specific companies. An environmental information system being implemented by the WDNR is expected to decrease the costs of copying, searching, and integrating relevant information; to speed delivery of information; and to ease records retention problems at the agency. A new data reporting protocol being tested would allow companies using the American National Standards Institute (ANSI) X-12 data standards to access the WDNR computing systems directly and submit the required data online. In fact, the future may bring direct links with company data systems such that the state agencies would not require annual reporting. Rather, state regulators might be provided with direct access to specific company environmental performance data sets that the company would routinely update for regulators.
The costs of maintaining and retrieving publicly requested information, however, can be substantial, even if done electronically. When facilities submit paper reports to state agencies, data from the report are entered into the database. Then it is stored and manipulated for billing and reports. Data entry operations cost time and money. Quality assurance for accurate data adds to the costs. For example, data comparisons with previous years' submittals are made to flag wide variations in data points so that agency engineers can investigate reasons for the wide discrepancies.
Electronic submittal of facility reports entails entering the data onto a computer diskette that is sent back to the state agency. As with paper-based reporting systems, resources are needed to support an electronic reporting system. For example, resources are needed to help first-time users with installing necessary programs as well as uploading and downloading information specific to each facility onto diskettes. In addition, technical staff is still needed to undertake quality assurance checks. However, responsibility for data entry errors rests with the company, not the state agency.
INCREASED PUBLIC DEMAND FOR INFORMATION
The mere existence of technology to increase public accessibility to environmental information has increased demand for information collected by state bureaucracies. Customers of state agencies (the public) are demanding that compliance and permit data be made available in electronic formats and be accessible on the World Wide Web (WWW). The spread of digital technology also has increased the demand for real-time information. Geographic information systems (GISs), which enable the collation, manipulation, and integration of spatial environmental information in ways not envisioned before, are being demanded by industry, government, and the public. This type of information can be used to show people the impact of releases from a facility or group of facilities. The GIS enables a visual map of an affected area to be overlain with a street map of the immediate area to give the public information about public risk.
Improved Environmental Protection
The reduction in emissions from industrial sources attributed to the TRI program has demonstrated the value of having a variety of environmental data compiled in one report and made widely available. The TRI requires certain facilities over a specified threshold to report releases of contaminants to the air, land, and water. This information is gathered annually and published for the public to review. Carol M. Browner, former administrator of the U.S. Environmental Protection Agency (EPA), observed that arming the public with basic information about toxic chemicals in their communities is among the most effective, common sense steps to protect the health of families and children from the threats posed by pollution. She pointed out that since the inception of the Community Right-to-Know program (under which TRI was implemented), reported releases of pollution into the community have declined by 46 percent (Kearns, 1997).
State agencies also have found TRI data particularly valuable in validating reports of various pollutants. For example, Wisconsin's air management staff have used their ITRS to identify the failure to report air emissions to the state's annual air emissions inventory, even though those emissions were reported under TRI. In the same way, Wisconsin also has begun using the ITRS at industrial facilities to ensure the quality of their own multiple reporting requirements and to ensure that all reporting is done accurately. Here the challenge is to use the data being collected to integrate single-media (air, land, or water) pollution reports, so that cross-media analysis can be done to help state agencies target companies that need assistance to minimize transfers of pollutants from one media to another.
INDUSTRY DEMAND FOR ENVIRONMENTAL INFORMATION
Aggregating environmental data enables more sophisticated analysis of environmental impacts of products and services and better environmental management and reduced risk. Progressive industry is interested in both product assessment and supply-chain environmental compliance performance.
Product or service assessments are based on the systematic, environmental review of the life-cycle steps associated with the product's component materials and manufacturing processes. Comprehensive analyses are called life-cycle assessments (LCAs). LCA has been used generally on products comprising few materials (Ehrenfeld, 1997; Owens, 1997). Aggregation of data across the product life cycle of energy and materials is a major feature of an LCA. However, there is a limit to the level of aggregation that is meaningful. Accumulating emissions from many different sites can lead to inappropriate conclusions if not integrated with other assessment techniques (Owens, 1997). Less-data-intensive, streamlined, or abridged analyses also are described in the literature. Several industries have effectively used streamlined matrix analyses on complex products (Graedel et al., 1995), processes (Eagan and Weinberg, 1999), and materials selection (Allenby, 1994).
Companies are also increasingly interested in the environmental performance of companies in their supply chains. Because of the consolidation of suppliers and a growing interdependence on suppliers and manufacturers to produce products and deliver services, the shared risk from environmental noncompliance or safety problems within supplier chains has become an issue for companies. Companies are therefore auditing suppliers for environmental risk (Anderson and Choong, 1997). Environmental performance data gathered on a supplier's compliance history and current status by state agency can be used by companies to estimate the quality of suppliers and judge the risks associated with those facilities.
CHALLENGES AND ISSUES RELATED TO IMPLEMENTING ENVIRONMENTAL INFORMATION SYSTEMS
Implementation of environmental information systems has not been easy despite the availability of technology. The implementation of WDNR's Fact System (see Box 1) revealed issues related to administration, public accessibility, and the interpretation of information.
Many administrative issues are associated with implementing a state-run environmental information system. The most obvious relate to designating responsibility for managing and administering the system. In the case of WDNR's Fact System, the small size of the databases envisioned suggests that it be run by the state even if some of the data are required for federal reporting. A problem that may arise from this approach occurs when the federal government or an industry wishes to integrate data from various states, but each state has a slightly different program with its own integration problems. With each state implementing its own system, data integration problems at the federal level are very likely to occur.
An anecdotal example in which one of the authors was involved demonstrates the next level of responsibility that relates to the data. In 1997, an environmental group in Wisconsin accessed ENVIROFACTS, an EPA public information tool on the Internet, which contains information from environmental reports made by facilities to the EPA. The environmental group proceeded to make a Freedom of Information Act request for Discharge Monitoring Reporting System information for all pulp and paper facilities in central Wisconsin. The EPA complied with the request, indicating that reports of the past two quarters from one mill were not in the system. The environmental group proceeded with a press release criticizing the pulp and paper mill and hinting at violations of the Clean Water Act for the missing submittal. In fact, the reports had been submitted to the state authority, but the EPA files had not been updated.
This example raises the question of where responsibility lies to ensure that publicly accessible data are up to date, of good quality, and used responsibly. In addition to being concerned that the data accessed may not be current, businesses also are concerned about putting incomplete data in an easily disseminated digital form when they submit the data to the regulatory agency. The public expects publicly available information, whether digital or paper, to be accurate. One might expect that it is the responsibility of the data providers to ensure that the information is accurate, that data keepers will be responsible for how the information is compiled, and that the user is responsible for reasonable interpretation.
There is growing concern about the possibility that individuals who have outside access to important databases will tamper with the data. Two options often mentioned are: (1) using a redundant database exclusively for public access or (2) using a firewall3 to protect the data and allowing read-only privileges. The use of redundant databases may be subject to uncertain financial support and the data currency issue described above. Hence, the use of firewalls is becoming common practice.
Finally, there can be data compatibility problems. Aggregating information from a number of different sources requires compatible data formats. For example, data on a single company that is derived from multiple regulatory reporting systems may be expressed in unrelated units of measure; denote toxins as elements, compounds, or mixtures; or list the facility by physical address or mailing address of a parent company. These inconsistencies must be reconciled prior to aggregating the data if reliable information is to be derived.
Public Accessibility Issues
Technical information traditionally has been delivered in writing or through personal contact. More recently, other alternatives have emerged to deliver technical information to as many people as possible using minimal resources. These methods include telephone conferencing, television broadcasts, videotape distribution, and automated faxing systems. The growth of the Internet has added electronic delivery of text through e-mail, file transfer protocols, gophers, and Web sites to the menu of options for transferring information. In addition, the use of e-mail listservers (where notices are sent to subscribers) and online database search engines has dramatically increased the availability of technical information to a wider audience. In the environmental protection field, this audience includes waste generators, regulatory agencies, technical assistance providers, and the public.
Electronic sources of environmental information, like other information, come in a variety of configurations. There are manually distributed databases for use on personal computers, interactive online databases that lead a user through a series of decision trees to locate information, online engineering and environmental library catalogs, and electronic information exchanges, such as e-mail listservers.
As states and the federal government move toward public access to electronic environmental data, questions arise about the technical capability of all citizens to access and interpret this information. While most public libraries provide access to the Web; finding and interpreting data can be a substantial barrier to the public. Public and private organizations are addressing this problem by indexing sources of information, compiling summary information on complex issues, and providing interpretation of environmental information (though often with a slant toward their own agendas).
The case for public access to environmental data is hard to dispute. No regulatory agency wants to say that their data cannot be made public; they are public agents empowered to enforce the laws. The debate over public accessibility revolves around how accessible the information is to the average citizen.
Wisconsin has an open-records law. Basically, all records reported to the WDNR, including environmental information, are open unless they meet the exclusion statute as a trade secret. By statute, there are two tests for a trade secret: (1) Has the company taken reasonable precautions to keep this information confidential? and (2) Would the release of the information cause the company to be put at a competitive disadvantage? Companies can request that certain information reported to the WDNR be kept confidential. Process-specific data, chemical usage, and production levels are the most common types of information protected as confidential. Much of the information gathered in annual reporting for the Air Emission Inventory includes company reports of production levels from which emissions are calculated using a standard set of emission factors--EPA air pollutant emission factors (AP-42). This causes concerns for highly competitive industries. Now that this information is easily accessible in electronic format, competitors can more easily gain intelligence that may influence pricing and competitive bidding.
Although environmental information always has been available in paper files or on microfiche, the authors are not aware of any evidence that an industry has taken the time to search through regulator's files to gain information on competitors. However, as profit margins shrink and competitors become more electronically adept, industries may look for any easily accessible competitive edge, such as evaluations of waste streams to reveal production processes or efficiencies.
Whenever the issue of public access to environmental data arises, an electronic data system is the first solution considered and the first funded. The public supports electronic data systems that are being designed by the government for the public's use. However, the average person needs to have the tools and training to be able to take advantage of these electronic data systems. Little research to date has explored how to raise the capacity of the public to embrace these electronic systems.
A fundamental problem with public access remains: Does the government collect environmental data that the public wants or can understand and meaningfully interpret? Local citizens want to know if they and their children can safely live near a manufacturing facility. Simply knowing that a manufacturing facility emitted 10 tons of permitted discharges into the air does not meet their need. Studies have shown that the American public is not well versed in environmental issues and may have limited knowledge to interpret the information (The Roper Organization, 1990). Although the government collects information for regulatory purposes, it may not know what information the public needs to make an informed contribution to the policy dialog. In all likelihood, the government has never asked.
Another accessibility issue pertains to environmental justice. Citizens living in heavily industrialized areas may not have the educational background and technical skills needed to interpret environmental data. Governments need to understand the range of skills of their target audience and then tailor information systems (electronic or otherwise) to them. Education to develop the interpretive capabilities of the public is also a possibility.
Any attempt to aggregate and interpret environmental information must cope with the variety of waste types generated by a large industrial community and with the different reporting requirements and metrics of state and federal environmental agencies and programs. For example, in southeastern Wisconsin, nearly 5,000 companies generate 100 million pounds of hazardous waste and toxic emissions each year, comprising more than 300 chemical and waste types.
These waste and emissions data are compiled by the following reporting systems: WDNR Resource Conservation and Recovery Act Annual Reports, EPA TRI Form R Reports, WDNR Air Emission Inventory, and WDNR NR101 Annual Water Discharge Summaries. The data are reported in the following units: total mass in pounds, mass in pounds of toxic constituent, or concentration in mass per volume of water or air. In most cases, the lack of comparability between the reporting metrics results in under- or overreporting of emissions when the data are aggregated for a single facility. Extensive analytical interpretation is required if meaningful information is to be derived (Liebl, 1992).
In addition to providing an accurate summary of environmental information, regulatory agencies and others can provide further data interpretation for specific audiences. Individual companies may want to know how their level of emissions compare to an industrywide benchmark. Citizen groups may want to see maps that show air emission distributions over populated areas. Policy makers may want to track progress in environmental performance over time. Each of these special needs requires substantial data manipulation and interpretive configuration, and clearly will cost money.
As technology continues to advance, so also will the information handling and analytical capabilities of companies, citizens, and public agencies to deal with the important issues related to the environment. The importance of making linkages between the environmental conditions and human activities continues to grow. The benefits of aggregating environmental information to support private and public decision making are certain. Making usable, environmental information accessible to the public while promoting the public's capabilities to interpret the information is a complex problem. Because access to aggregated environmental information appears to be valuable, the administrative and implementation barriers that prevent society from taking advantage of this technology must be addressed.
The authors acknowledge the contributions of Tom Aten, WDNR; Nicholas Bouwes, EPA; Ken Brown, Minnesota Office of Environmental Assistance; and John Stolzenberg, Wisconsin Legislative Council.
The authors dedicate this chapter to Lynda's husband, Jeff Edge, and their daughters, Julianna and Lindsey.
1 Issues such as property rights, described by Branscomb (1985) and Cohen and Martin (this volume), or other legal issues surrounding the submittal of electronic data or the confidentiality of personal information are beyond the scope of this paper.
2 The Environmental Protection Agency is authorized under the Superfund Amendments and Reauthorization Act Title 313 to collect and disseminate information on the release of toxic chemicals to the environment. These data are compiled annually into the TRI.
3 A firewall is an approach to computer network security; it helps implement a larger security policy that defines the services and access to be permitted, and it is an implementation of that policy in terms of a network configuration, one or more host systems and routers, and other security measures such as advanced authentication in place of static passwords.
A firewall system can be a router, a personal computer, a host, or a collection of hosts, set up specifically to shield a site from protocols and services that can be abused from hosts outside the site.
The main purpose of a firewall system is to control access to or from a protected network. It implements a network access policy by forcing connections to pass through the firewall, where they can be examined and reevaluated.