         Improving the Display of Facility Compliance History in ECHO

1 - Issue Summary

U.S. EPA and states are cooperating to improve the display, usability, and accuracy of EPA's Enforcement and Compliance History Online (ECHO). ECHO is a critical tool for accessing and analyzing information about facilities regulated under the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Safe Drinking Water Act. ECHO supports transparency of compliance and enforcement data and program management. ECHO aggregates information across regulatory programs and across state, tribal, territorial, and federal regulatory authorities. In doing so, ECHO must account for considerable variation among programs and agencies and display information about regulated facilities that is accurate, understandable, and helpful to the public, the regulated community, and partner agencies. Placing data in the proper context for ECHO users requires thoughtful design, careful selection of terminology, and informed use of the available data.

As co-regulators, states and EPA are committing to a process that will enable more collective stewardship over the presentation, accuracy, and completeness of data in ECHO. That process will ultimately produce a model for joint governance, communication, and decision-making. We expect that this cooperation will boost ECHO's usefulness, accuracy, and impact.

As a first step, a team of state and EPA representatives has identified some changes to ECHO that will enhance the user experience and improve ECHO's display of facility compliance-related data. After seeking stakeholder input on these proposed changes, the team is now recommending that EPA implement these changes in ECHO Lab so that co-regulators can view the changes and ensure that they meet their needs.

2 - Changes Impacting All Media

 ECHO will discontinue use of the term "Compliance Status" on facility searches and the Detailed Facility Report. Instead, ECHO will use the label "Compliance History" to avoid the implication that the current compliance status of a facility is known. (For example, on the Detailed Facility Report, the "Three Year Compliance Status by Quarter" table would be labeled "Three-Year Compliance History by Quarter".)
 Eliminate the 12-Quarter Violation History grid that appears at the top right of the Detailed Facility Report. 
 On the detailed Facility Report, violation details table (currently "Three Year Compliance Status by Quarter"): 
 By default, display compliance history information by month and provide a user with the capability to toggle between the quarterly history display. 
 Violation periods (non-HPV/SNC) will be labeled with the text "Violation Identified" (rather than "In Violation") with help text to indicate that a violation was identified during the displayed time period; in subsequent periods in which violations remain unresolved, based on the lack of a Resolved Date in ICIS-Air, the text will read "Violation-Unresolved" to indicate that one or more violations are unresolved but not newly identified. These new labels will present the data in a more appropriate context because the available information cannot support determinations about a facility's up-to-the-minute compliance status. 
 Periods without a violation will display blue boxes indicating "No Violation Identified". This also applies to the Enforcement and Compliance Summary at the top of the Detailed Facility Report. 
 ECHO will now provide the date of the last data refresh on the Detailed Facility Report.

3 - Changes Impacting Clean Water Act Data Only

 Detailed Facility Report, violation details table:
 ECHO will add the ability for the user to display all monthly DMR exceedances in a quarter (currently, only the worst monthly exceedance in a quarter is displayed). If there was no DMR exceedance during a given month, the user also will see that reflected.
 For NPDES DMR non-receipt violations, the team recommends that ECHO display information to distinguish between DMRs received late versus not at all, if the source system can be enhanced to allow for this. 
            
4 - Changes Impacting Air Data Only

Many agencies have expressed an interest in optionally displaying a more precise date range for Federally Reportable Violations (FRVs) in ECHO. Agencies will now be able to select their preference from one of the options below. The intent is to support all three of these display options and allow agencies to choose the one that offers the best fit for their circumstances.

Option 1a: Violation Identified  -  WITH Date Range using Determined to Resolved Dates
On the Detailed Facility Report, ECHO will display violations with the label "Violation Identified" or "Violation" in a given time period (quarter or month) AND ECHO will display the start and end dates of the FRV using information from ICIS-Air. ECHO will use the FRV Determination Date as the Start Date for an FRV. Agencies will voluntarily populate that field in ICIS-Air with the date that is most appropriate for their program's policies and procedures (consistent with the 2014 FRV Policy). ECHO will use the Resolved Date from the ICIS-Air Case File as the End Date for an FRV. Agencies will voluntarily link formal enforcement actions to the case file containing FRVs where applicable, and in the absence of formal enforcement, populate the Resolving Action Type and Date fields with the action type and date that are most appropriate for their program's policies and procedures. 

Option 1b: Violation Identified  -  WITH Date Range using Occurrence Start and End Dates
This option is identical to Option 1a, but it would use different sources of FRV start and end dates. Under this option, ECHO will use the Violation Occurrence Start Date as the Start Date for an FRV and the Occurrence End Date as the End Date for an FRV. Agencies selecting this option will voluntarily populate the Occurrence Start and End Dates. Please note that this option will require a change to an ICIS-Air business rule because these data fields are currently part of a sensitive area of ICIS-Air that is unavailable for extract to ECHO. Also, it's possible to have multiple violations on a case file with different time periods. Further discussion would recommend how violations should be displayed when there are multiple violations for a case file with different occurrence dates.

      Option 2: Violation Identified  -  NO Date Range 
      On the Detailed Facility Report, ECHO will display violations with the label "Violation Identified" in a given time period (quarter or month). This option continues current practice in which ECHO uses the FRV Determination Date in ICIS-Air to drive the display of an FRV without a date range. The FRV Determination Date is either reported voluntarily by the agency or auto-generated by ICIS-Air to match the date on which the agency submitted the violation data to ICIS-Air. Under Option 2, ECHO will also display explanatory text that reads "Resolved Not Indicated" to inform a user that ECHO doesn't have data on when a violation was resolved. 
   
New ECHO Explanatory Caveat
      
Offering multiple FRV display options gives agencies the flexibility to choose a solution that best fits their own circumstances and programs. However, this will also result in some inconsistency in how FRVs are displayed in ECHO and how individual agencies define these date fields. The team has developed the following caveat language for the ECHO website to help users understand the variation among agencies' information:

   EPA requests state and local environmental agencies provide data associated with Federally Reportable Violations (FRVs) that is thereafter displayed in ECHO. These agencies submit data in accordance with minimum EPA requirements. In so doing, these agencies have varied processes for how they provide such information. To accommodate for this variation in FRV reporting, EPA has updated the ECHO display of data to allow the states/locals to choose to report FRVs consistent with one of the following approaches:

 Agencies use the FRV Determination Date and the Resolved Date to display an FRV date range in ECHO. These include...
 Agencies use the Violation Occurrence Start Date and the Occurrence End Date to display an FRV date range in ECHO. These include...
 Agencies use the FRV Determination Date to display in ECHO the date when the FRV was identified. These include...

Note Regarding FRV Data Reporting

Data elements that drive the display of FRVs in ECHO (such as the fields discussed above) are not currently required by the ICIS-Air Information Collection Request (ICR). States/locals and EPA have noted that this can contribute to inconsistencies among data from different agencies and that it also differs from reporting requirements for High Priority Violations (HPVs). As a long-term approach to addressing issues with FRV data, states, EPA, and other stakeholders may wish to jointly consider the value of streamlining and modifying the required data set under the ICIS-Air ICR. The content of the ICR is due for reconsideration in advance of its expiration in January 2019.
