ECHO Comments Archive

"Thank you for making available the history of our local compliance. This is useful information for the citizens of Butte as well as for our local government and legislators."
- Academic user

"If the ultimate goal of ECHO is to make compliance histories more accessible to the general public, the presentation format needs to be made much less cumbersome and confusing for those who are not environmental professionals. For example, referring to reporting periods as Qtr1, Qtr2, etc. may appear to be very logical, but will not make much sense to a member of the general public who is simply trying to relate the data to the real world. This will especially be the case as numerous quarters go by, and the periods become Qtr100, Qtr101, etc. I suggest that you use a much simpler system that will be readily apparent to everyone (i.e, 1Qtr2003, 2Qtr2003, or something similar). Likewise, the use of a non-standard abbreviation like "Nmth" could be very confusing, and while it is defined in the data dictionary, it's buried in pages of text, and my opinion is that the average citizen will most likely give up and become frustrated before they can find it, which will not give them a very good impression of the site as a whole. I suggest that this term (and others like it that are not immediately recognizable) be defined in footnotes on the same page and directly below the table where they appear, not in a completely different location that forces the user to go a lot of extra effort to find out what it means. Again, the general comment and observation here is that if the intent is to make this type of data more accessible to the public, it should also be presented in a way that is much easier for the public to find and understand."
- Regulated entity user

"Thank you for the opportunity to comment on the utility of ECHO. Over the past few days I have conducted several queries using ECHO and have found it to be a useful and informative source of information. I believe this type of information and access is in the best spirit of open government and will reduce paper based FOIA requests, thus reducing paperwork. I would strongly urge the agency to continue providing ECHO. My only suggestion would be to enhance the search feature to allow more structured inquiries."
- Commercial user

"USEPA should remove the web site from the internet until such time that the data presented is quality controlled and correct. Incorrect, dated, and misleading information serves no good environmental purpose and does nothing to enhance the public availability of such information."
- Regulated entity user

"We believe the dates noting non-compliance in sections "Compliance Summary Data and Two Year Status By Quarter" are misleading. The ECHO database should allow for comments noting the status of corrective actions. Noting the status of corrective actions would be more accurate and responsive to public concerns. Basing compliance status solely on the date of penalty resolution is not appropriate and is misleading to the public."
- Regulated entity user

"Please keep all information on the ECHO website open to the public. It is vital for all citizens to know what chemicals are being released and by whom into our innocent looking air. The information can be used by residents and the press to inform the public about what can be done to protect human health. Thank you."
- Unaffiliated user

"I believe the ECHO site has a great deal of valuable information to offer patrons of my library, whether students in the Sciences or Political Science, or citizens using the Law Library which is also housed in our facility. Please retain and extend this site."
- Academic user

"Very informative site! A useful tool for anyone in the environmental field"
- Commercial user

"This site is very important to our environment. Please keep the data permanently available to the public. Thank you."
- Unaffiliated user

"I just want to commend the EPA for putting this database online. It is a valuable resource that should be open to the public. Environmental woes are shared by the whole nation and so the knowledge of them should also be shared."
- Unaffiliated user

"I thank the Agency for making compliance data under our most important public-health laws such as CWA, CAA, and RCRA available to the public, online. The right-to-know provisions have been beneficial in helping affected industries better monitor their processes, reduce harmful discharges and toxic-materials use, and therefore better protect communities and citizen's health. I commend the EPA for making compliance history data available, for informational and decisional use by local people. [xxx], I find some features of your website information very helpful, for example 1) information on facility status, ie. whether in noncompliance or significant noncompliance, and time period and discharge point 2) environmental status of receiving waters 3) compliance history of a facility over the last eight quarters. The website could be helpful in some additional ways and I would like to suggest certain other information that I often seek to gain from various sources; perhaps they could be included on the ECHO site: 4) Both major and minor discharges are important, the latter because cumulative effect can be serious 5) Notices of violation taken by state agencies or EPA should be included; it is desirable to learn when and how the violations have been corrected 6) Toxic Release Inventory data should be included and, if possible, CAFO and stormwater permit information 7) More detailed information on inspections, eg. when, where, and by whom performed 8) Quantities discharged should be shown instead of percentages only. Again, I thank the Agency for the website start. Thank you for considering my comments."
- Unaffiliated user

"During this comment period, I wanted to voice my opinion. I have used ECHO from the day you went live and enjoy it. I think the concept, to ease of use, design, make it a valuable tool. To all the ladies and gentlemen it took to make it happen, I thank them. This was truly an undertaking."
- Commercial user

"Your website /echo/ is wonderful. I just looked up where I live, and where I plan to live, and found some interesting and very unexpected violations, like the [xxx]. Besides the great service to the public, the website has the effect of encouraging the violators to clean up their acts and remove their violations as soon as possible. Of course, violators would prefer the information not be available. What a great way to spend taxpayer dollars frugally and effectively! Please continue to expand and improve this website."
- Unaffiliated user

"The site provides some good information that allow residents within the communities and consumers make better educated decisions regarding the services these companies provide. For example, it allows consumers to choose cleaners with no negative entries. ECHO would be even more beneficiary if it provides further information on the type or impact of violation (e.g., chemicals, side affect of chemicals, volume of violation, environmental impact of violation). I hope you anticipate to expand this site and database and assure that it will be available to all citizen for the upcoming years."
- Unaffiliated user

"...maybe you could make [the advanced search] more noticeable? I went right to the search field in the middle of the page without seeing those links on the side. The search field draws your attention. Maybe you could have a link right under or next to the search field that says Advanced Search"?"
- Commercial user

"...We commend the EPA for beginning the process of placing critical information on environmental permit compliance and enforcement in a database easily accessible to the public. This information will assist citizens in obtaining information about whether facilities in their towns and neighborhoods are in regular compliance with their permits. It will also allow companies with good compliance track records to spotlight those accomplishments and encourage those companies violating their permits to cleanup by exposing their record to public scrutiny. As EPA already maintains this information, there is no sound reason to force members of the public to file a Freedom of Information Act request in order to obtain information that can be easily put on the web in a searchable format. To continue to withhold this information in the age of the Internet is unnecessary, and fails to take advantage of new technologies that make government initiatives more transparent to the American citizenry. Again, we thank EPA for beginning the work to make this information available to public.
That said, there are limitations within the ECHO system that can be improved upon to make this information more useful, accurate and user friendly. We submit the following areas for improvement: In its current form, the ECHO system puts some users through a tedious process to find and extract the relevant data needed from the voluminous information contained in each report. A data sorter, such as the one used in the Toxics Release Inventory website, would allow users to find specific data without having to navigate through the labyrinth of information provided in each report. Such a sorter should allow the user to pick one or more fields and generate a report with only that information. The Permit Compliance System currently includes information on stormwater, general, pretreatment and CAFO permits, but this information is not yet available on ECHO. There is no reason why this information should be excluded. ECHO should include more pollutant release data such as: air emission inventory, hazardous waste generation (from Biennial Reporting System), and overall permitted loadings for each Clean Water Act chemical. EPA should consider combining the information provided on ECHO with that in the Toxics Release Inventory. Although providing information on inspections and violations can be useful to the public, it does not provide the entire picture. Linking these two databases would go a long way towards making this new program an effective tool for communities to protect their quality of life. An example of this problem is the report on the [xxx] in [xxx]. The "Facility Characteristics" Chart showed that under the Clean Water Act, an NPDES permit was issued to [xxx] with a facility status of "Major Active". This permit expired in June of 1997. The next chart, "Inspection and Enforcement Summary Data", showed that no penalties were administered even though several inspections had taken place. Further down the report the "Compliance Summary Data" stated that the facility was in non-compliance for 8 quarters. However, the following chart, "Two Year Compliance Status by Quarter" did not show a single quarter in non-compliance. Combining this data with information available in the Toxics Release Inventory allows the user to see that the [xxx] is still discharging large amounts of chemicals into the [xxx] on an expired NPDES permit. This ! illustrates the need to expand the information available through ECHO and to link it to other databases such as the Toxics Release Inventory in order to provide a comprehensive summary of each facilities compliance and total emissions. ECHO should include Notices of Violation taken by EPA or states. ECHO should allow searching for spills reported to the emergency response notification system (ERNS). ECHO has the potential to be an important citizen tool to protect communities and the environment. We applaud the EPA for making this information available to the public, and strongly urge the Agency to not only continue making this database available, but to expand and improve it."
- Public interest group user

"I want to commend EPA for providing the valuable data that is available on the ECHO website. The public has a right to know about the pollution that is being emitted into our air and waterways and its sources, and our government agencies have a responsibility to provide us with that information. Even though this is an excellent site, there is still more information that could be provided. Don't stop here. Keep it coming."
- Unaffiliated user

"I would like to comment on your inclusion of demographic data along with the other data in this database. Although I am sure those that would want to know this data would be able to find it in other ways, it seems like asking for trouble when this data is provided together. Since 9/11/02, I thought we should all be trying not to provide data that can be misused. I think that especially for large communities, the demographic data provided here is unnecessary and detrimental."
- Regulated entity user

"The following is a bulleted list of proposed comments and suggestions regarding the Enforcement and Compliance History Online ("ECHO") public database.
Solicited EPA Question (1): Does the site provide meaningful and useful information about the compliance and enforcement program? Comment: No. The site presents an excessive amount of information that is overwhelming to members of the general public who are not environmentally sophisticated and trained in environmental law jargon. While some of the information may be helpful, the general public only needs enough information to determine whether a facility is in compliance with the various environmental laws. There are too many acronyms which may seem second nature to environmental professionals but which are overwhelming and confusing to the general public. Furthermore, there is so much information that it will take a considerable amount of time, and it may be impossible, for a facility to determine whether its own information is correct. Additionally, the NPDES data is excessive and not presented well.
Solicited EPA Question (3): Does the help text adequately explain the data? Comment: No. For example, ECHO includes a link to an Air Releases (AIRS/AFS) data page. After running a query on that page, the system returns certain data including data for each AIRS/AFS Plant Point. One entry in the AIRS/AFS Plant Point information table displays whether the Plant Point was in Compliance or Emission. The entry for my client on that line simply says "Emission." However, after clicking on the Compliance or Emission help link for an explanation, the system returns explanations for several confusing codes, none of which are used for the entry on that line. The entry merely says "Emission." This is confusing and not helpful.
Solicited EPA Question (4): What additional features, content, and/or modifications would improve the site? Comment: Less information and more accurate information. For instance, when a query is run on my corporate client the query results include a company no longer affiliated with my corporate client. As a result, if that un-affiliated company were not in compliance it would appear that my client was also out of compliance. Also, the sheer volume of information is overwhelming and confusing.
Solicited EPA Question (5)(A): Were your facility reports accurate? Comment: No. When a query is run on my corporate client the query results include a company no longer affiliated with my corporate client. Also, based on the report format, my client was unable to determine the accuracy of the information."
- Regulated entity user

"The USEPA should remove the web site from the internet until such time that the data presented is quality controlled and correct. Incorrect, dated, and misleading information serves no good environmental purpose and does nothing to enhance the public availability of such information."
- Regulated entity user

"Thank you for the diligent and thoughtful work in putting together the ECHO website. Please keep this service intact, it is of great value to the nation."
- Federal government user

"As an environmentally-concerned taxpayer in two diverse states, I find ECHO to be a valuable information resource. EPA staff who developed this detailed yet user-friendly site are to be commended."
- Unaffiliated user

"I used the ECHO system for the first time today to find information regarding a [xxx] in [xxx] that was of interest to one of my environmental consulting clients. I found the system very easy to use and very, very helpful. Please implement it on a full scale."
- Commercial user

"...we fully support and endorse the ECHO concept of sharing important information with the public. It is the right of the public to be informed of environmental conditions around them. We strongly encourage the EPA to continue this valuable program."
- Public interest group user

"The current systems limits the results to 500 facilities. This makes it difficult to export all documents witinin a specific region or SIC code to a text delimited file to perform a statistical analysis of the data."
"I was trying to get an idea of the total number of companies within a given SIC universe. What I ended up doing was breaking it down by regions. Take a look at OSHA's site and they allow you to set a limit on the number of results returned..."
- Commercial user

"...Your site is well designed and easy to navigate with a lot of different search tools..."
- Unaffiliated user

"I want to request that this web site, and the information there in, CONTINUE to be available to the public ... on into the future. For a free country and a healthy planet it is vitally important that we have access to this kind of information unconditionally. Thank you"
- Unaffiliated user

"Re: ECHO in general Our facility supports the notion of a "one-stop shop" for all interested stakeholders to be able to access our environmental compliance history. However, as currently constituted, ECHO is not sufficiently sophisticated to deliver on that notion. The reason is that ECHO's inspection information is not linked to the [xxx] (which enforces CAA regulations at our facility) or to the [xxx] (which enforces RCRA and CWA regulations at our facility). In point of fact, our facility has been inspected more than four times in the last two years on these federal-level requirements, but ECHO does not display the results of any of these inspections, thus misleading the public to think that no inspections have occurred. Re: ECHO in general The name/acronym "ECHO" implies an emphasis on enforcement activities. We understand that this is a convenient and catchy acronym. However, we feel that starting with "enforcement" implies a negative connotation that tars the vast majority of facilities included in this data program that have demonstrated continued compliance with environmental requirements through repeated inspections. Re: TRI data reporting When a facility utilizes a data range for release reporting (ie, Code A = 1 to 10 pounds, Code B = 11 to 499 pounds, Code C = 500 to 999 pounds), the database should report the range code and the associated numeric ranges. Instead, what it does is it arbitrarily reports the numerical quantity that represents the midpoint of the data range. One of the cardinal rules of data display is to report the original raw data. The assumption inherent in the TRI database transformation of the range codes violates this rule. In our case, the transformation results in a release number that is more than an order of magnitude greater than what in fact our facility calculated."
- Regulated entity user

"The Facility Permits and Identifiers section should include actual Federal and State Permit Numbers or account numbers. The Two Year Compliance Status by Quarter section seems to have incorrect information. Correct information (i.e. air compliance status by quarter)needs to be available to ensure there is no Public misconception on a facilities actual compliance history so facilities are not forced to do needless work to mitigate incorrect compliance information. Explanations on violations indicated should be made available. If information is posted on the echo site (i.e. two year compliance status) a facility should have the right to review all data before hand to ensure and certify its authenticity."
- Regulated entity user

"[xxx] has long believed that social responsibility can be a fundamental indicator of long-term company performance. We would like to convey our support for your efforts to make information available through the Enforcement and Compliance History Online (ECHO) program. In response to your specific questions: 1) We find the ECHO site easy to navigate; 2) The help text adequately explains the data; and 3) the facility-level enforcement and compliance information is useful. However, we do have some suggestions for improvement. Additional content would improve the site, most notably the businesses that own each facility should be identified. Tying regulated facilities to their corporate owners would enable the public, peer companies and investors like [xxx] to more accurately assess environmental performance. To be truly useful, ECHO should provide company-level enforcement and compliance information. We congratulate you on your hard work in developing ECHO and urge you to continue to make it available to the public. We hope our comments will be incorporated in future improvements."
- Commercial user

"This site is an excellent tool for environmental project administration. When all data is complete, this will be an excellent way to begin due diligence when searching for a waste hauler, or other environmental firms. The ability to check and correct errors is excellent to ensue the integrity of the data. Also for those of us complying with ISO-14001, this presents an excellent compliance verification tool. The communication of ECHO's availability or creation has been limited. Our corporation received no notice or communication of the creation of this data-base, but found it through an article in a trade publication. Businesses should be notified of the changes to the way public information is to be presented."
- Regulated entity user

"Upon review of the ECHO website, a quality check of our company's data and from using the process by which data corrections are made, we would like to make the following comments: 1. There is no security in place to validate the authority or credibility of submitted data corrections. It appears that any persons submitting data corrections electronically from the domain of the subject company can alter the data. Our largest facility with data displayed in ECHO has over [xxx] employees, most of whom have Internet and email access, however, only a few employees have the authority to speak credibly to the data. EPA needs to establish a process that validates information submitted on behalf of a regulated entity. 2. We question whether the ECHO website data "provide a snapshot of a facility's environmental compliance record." The data shows a record of violations out of context of the scope of the facility's entire environmental compliance challenges related to characteristics such as facility size, type and diversity of business activities, or facility age. Further, those same characteristics generally determine the level attention a facility receives from local, state and Federal enforcement authorities. Both of these short comings would tend to distort the data and could give a biased picture of compliance. 3. Publication of data of this type with minimal supporting information seems to unfairly cast a facility in a negative light while the facilities that are included are often those that are actively complying with environmental regulations. These regulations are very complex and frequently the violations amount to "paperwork" errors that result in no actual harm to the environment. Facilities that avoid compliance, particularly reporting requirements, would tend to avoid the stigma of published violations as they may "fly under the radar" for some time. 4. The data for "Effluent violations by NPDES parameter" would be much more meaningful if the underlying permit limit data are provided. Presented as a percentage the reader would have to know the permit limit to determine the quantity of the exceedance. Permit limits vary greatly by parameter."
- Regulated entity user

"The information provided by this site has been applied to both professional projects and personal interests. As an environmental scientist, I am constantly verifying information from as many reliable sources as possible. What this site offers is an important tool for the technician, the public, and the individuals who form policy. I would strongly recommend the continuation of the site."
- Regulated entity user

Phoned comments

This site has proven to be extremely helpful. All in all, this has been extremely helpful for the caller's Compliance and Enforcement. Suggestion: Increase the search query output more than 500 facilities, even if it is just a list of the facility names and addresses, and the DFRs are not viewable.
- State/local government user