03/
08/
2003
The
questions
and
answers
are
arranged
in
four
categories:

0
General
Implementation
of
the
Data
Standard
0
Use
of
the
Data
Standard
Technical
Questions
for
Implementers
General
Questions:

Q1:
A:
What
is
the
Permitting
Data
Standard?
A
"
data
standard"
is
a
documented
agreement
among
organizations
that
share
or
exchange
data
regarding
representation,
formats,
and
definitions
for
such
data.
The
Permitting
Data
Standard
provides
a
common
vocabulary
to
be
used
by
EPA,
States,
Tribes,
and
local
govement
agencies
that
want
to
share
data
about
environmental
permitting
activities.
The
Data
Standard
is
made
up
of
a
list
of
data
elements,
each
of
which
is
defined.
Relationships
or
linkages
among
data
elements
(
both
within
the
Permitting
Data
Standard
and
between
it
and
other
data
standards)
are
also
identified.
I
Q2:
A:
Why
was
the
Permitting
Data
Standard
revised?
The
Permitting
Data
Standard
was
revised
to
broaden
the
scope
of
the
standard,
to
better
address
the
full
life
cycle
of
the
permitting
process,
and
to
more
comprehensively
represent
the
complexity
of
multimedia
permitting
programs.
The
initial
Permit
Data
Standard
Action
Team
in
2001
decided
to
develop
a
simple,
high­
level
standard
that
includes
core
data
­
information
sufficient
to
identify
a
permit,
as
well
as
some
information
on
administrative
status
and
history
­
that
is
common
across
most
organizations
and
programs.
While
programs
may
have
the
need
to
exchange
more
program­
specific
information
relating
to
permits,
the
EDSC
decided
that
the
original
standard
should
be
expanded
prior
to
developing
program­
specific
standards
to
avoid
duplicating
similar
information.

Q3:
A:
What
changes
were
made
to
the
Permitting
Data
Standard?
Minor
changes
were
made
to
the
definition
and
relationship
portions
of
the
standard,
and
additional
data
elements
and
definitions
were
added
to
the
standard
to
better
characterize
facility/
feature
characteristics,
permit
conditions,
and
control
methodology
information.
A
number
of
contact
related
data
elements
that
were
originally
part
of
the
Permitti
the
Contact
Data
Standard
that
w
identified
a
distinction
be
are
sufficiently
similar
to
captured
in
the
revised
definition
of
"
permit"
which
appears
in
QlO.

The
standard
refers
to
"
relationships"
with
other
standards,
such
as
the
Facility
Identifier
and
Chemical
ID
standards.
Does
this
mean
that
these
other
standards
are
included
in
the
Permitting
Standard?
How
would
this
work
in
practice?
A:
Because
environmental
business
enforcement
actions
against
org
areas
are
also
interrelated.
For
ex
information
(
defied
in
the
Fac
parameters
(
defied
in
the
C
reinvent
or
duplicate
these
e
and
refers
to
other
standard
Standard
have
been
removed
because
they
are
contained
in
approved.
In
addition,
the
permitting
11
Action
Team
en
permits,
licenses,
and
certifications
and
believes
that
permits
and
licenses
considered
together
where
as
certifications
do
not.
This
clarification
is
Q4:

errelated
(
e.
g.
facilities
have
permits,
agencies
take
core
information
that
is
part
of
a
permit
includes
facility
own
facilities
and
have
permits..
.),
the
standards
for
these
on
standard)
and
information
about
chemical
and
biological
ion
and
Biological
Taxonomy
standards).
Rather
than
Action
Team
has
identified
some
of
these
relationships
Q5:
A:

Q6:
A:
The
way
in
which
such
a
relationship
would
be
applied
is
best
understood
in
the
context
of
a
"
transaction"
or
exchange
of
data.
Simple
incorporation
of
existing
standards,
such
as
the
Date
Data
Standard,
is
straightforward;
one
simply
uses
the
prescribed
format
for
the
data
element
in
the
exchange
e
necessary
to
link
two
or
covered
by
its
own
Stan
distinct
records
(
e.
g.,
Permit
itting
a
set
of
permit
records
from
one
organization
to
another
using
common
sheet
or
fixed
for
e),
it
would
be
necessary
to
include
to
which
the
permit
is
issued
(
this
anying
facility
file,
consistent
with
the
Facility
ID
standard.
If
Facility
ID,
or
other
information).
Additional
facility
that
information,
the
unique
facility
mical
or
biological
parameters
d
in
analogous
fashion.

Standard­
is
this
aother
federal
mandate?
e.
The
decision
to
develop
Data
Standards,
including
the
ointly
by
EPA
and
the
States
(
through
The
Environmental
Council
ation
that
represents
the
heads
of
the
state
environmental
agencies).
All
anging
accurate
data
is
important
and
will
remain
so.
All
recognized
s
and
deserves
to
have
access
to
compilations
of
current
data
about
.
Together,
they
established
the
Environmental
Data
Standards
ide
the
process.
Action
Teams
are
established
to
develop
data
made
of
representatives
from
EPA
and
the
States
and
are
co­

data
elements?
There
are
many
different
environmental
programs,
and
many
different
government
agencies
involved
in
environmental
permitting.
Often,
these
different
programs
or
different
permitting
agencies
use
different
names
to
describ
of
a
permit.
In
other
instances,
activities
or
instruments
with
the
same
or
similar
names
are
te
different.
For
example,
different
state
agencies
may
use
terms
such
PDES
permit
or
NPDES
permit
to
refer
to
similar
things
­
permits
rovisions
of
the
Federal
Clean
Water
Act
(
and
equivalent
state
enabling
ging
to
waters
of
the
United
States.

If
data
from
different
programs
and
different
agencies
are
to
be
shared,
it
is
important
that
we
identify
uniformity,
regardless
of
what
they
are
called
or
named
by
the
source
of
the
data.
In
other
words,
we
need
to
make
sure
thht
apples
are
compared
to
apples,
even
if
we
know
that
some
are
"
Golden
Delicious"
and
some
are
"
Granny
Smith."

Implementation
of
the
Data
Standard:

Q7:
A:

QS:
A:
Will
my
agency
(
or
my
program)
be
required
to
use
the
Permitting
Data
Standard?
No
State,
Tribal
or
local
government
agency
or
program
is
required
to
adopt
or
use
the
Permitting
Data
Standard,
nor
to
incorporate
it
into
that
agency's
or
program's
own
data
systems.
However,
once
EPA
and
state
agencies
adopt
and
begin
implementing
the
Data
Standard,
it
will
likely
become
the
specified
"
road
map"
for
communications
among
environmental
agencies
exchanging
environmental
permit
information.

When
is
the
Permitting
Data
Standard
anticipated
to
be
approved
by
ECOS
and
EPA?
The
Permitting
Data
Standard
was
approved
by
the
EDSC
in
December
2001
and
by
the
EPA
in
April
2
Q9:

A:
~

I
I
Q10:

A:

Q11:

A:

Q12:

A:

Q13:

A:

Q14:
the
revisions
to
the
Permitting
Data
Standard
will
be
completed
003
by
the
EDSC.

g
Data
Standard.
What
will
I
a
elements
that
were
in
the
pr
captured
under
another
d
a
number
of
facilities
and
other
entities
that
have
licenses
or
authorizations,

control
document
used
to
implement
the
ents
not
specifically
called
permits,
but
gulated
or
are
of
interest
to
ment
agencies.
For
example,
the
current
definition
would
not
include
TRI
work
for
exchanging
information
about
this
broader
set
of
regulated
entities.

Can
some
programs
within
a
State,
Tribe
or
local
government
follow
the
Permitting
Data
Standard,
while
others
do
not?
Use
of
the
Permitting
Data
Standard
is
not
required,
although
over
time
it
may
become
the
standard
for
sharing
or
exchanging
data
with
EPA
national
data
systems
through
the
Exchange
Network,
as
well
as
between
state
agencies.
See
Question
19
for
additional
information
on
the
Exchange
Network.
State,
tribal
or
local
government
programs­
especially
those
that
d
not
exchange
data
with
EPA,
other
Federal
agencies
or
agencies
in
other
states­
are
mainly
not
obliged
to
adopt
or
work
within
the
Permitting
Data
Standard.
However,
as
it
becomes
a
widely
accepted
standard,
they
may
find
it
useful
to
use
it
in
data
management
and
exchange.

I
am
from
a
State,
Tribal
or
local
government
agency.
My
program
doesn't
use
the
same
data
elements
that
are
used
in
the
Permitting
Data
Standard.
Is
there
an
expectation
that
we
will
change
our
data
elements?
No.
The
Data
Standard
uses
terminology
intended
for
data
exchange
and
is
applicable.
only
when
the
data
that
is
sent
crosses
the
threshold
of
your
organization.
Similar
data
that
are
exchanged
will
need
to
map
to
existing
data
holdings
or
conform
in
definition,
meaning,
and
format
to
the
Standard.

My
EPA
program
doesn't
use
the
same
terms
as
are
used
in
the
Permitting
Data
Standard.
Is
there
an
expectation
that
we
will
change
our
terminology
to
match
the
standard?
Although
the
Data
St9dard
is
intended
for
use
in
data
exchange,
it
is
expected
that
EPA
programs
will,
as
necessary
(
and
over
time),
modify
the
data
elements
that
they
currently
collect
to
conform
to
the
data
elements
and
terms
in
the
Permitting
Data
Standard.
The
schedule
for
these
changes
will
be
addressed
in
the
Business
Rules
that
provide
implementation
guidelines
specific
to
the
Agency.

Is
the
Permitting
Data
Standard
the
basis
for
a
new
data
system
design?
Will
we
have
to
change
our
existing
data
system
to
conform
to
it?

\

3
A:
agencies
is
No.
The
Permitting
Data
Standard
is
or
authorizations
"
mapped"
to
the
correct
ose
to
use
this
Data
Stan
Q15:
We
are
pl
data
system(
s).
Can
the
A:
or
agency
is
planning
to
update
its
existing
data
system(
s),
the
us
in
this
effort?

a
useful,
peer­
reviewed
template
for
the
kinds
of
data
that
current
good
Q16:
Are
there
any
federal
funds
available
to
help
States,
Tribes,
or
local
government
agencies
that
ey
choose
to
update
their
systems
to
enable
them
to
communicate
Data
Standard?
linked
directly
to
the
Permitting
Standard
development
effort.
EPA
assistance
has
often
been
used
by
grantees
to
help
develop
and
update
A:
Yes,
although
funding
to
assist
other
levels
of
government
that
implement
federal
environmental
programs.
data
management
systems.

Q17:

A:
There
are
a
number
of
data
elements
listed
in
the
Permitting
Data
Standard
that
we
don't
currently
record
or
track
in
our
own
data
system.
Will
we
now
be
required
to
do
so?
No.
The
presence
of
a
given
data
element
in
the
Permitting
,
Data
Standard
does
not
create
a
new
data
collection
requirement.
State,
Tribal,
and
local
government
systems
do
not
need
to
begin
collecting
all
data
for
which
there
are
data
elements
in
the
Data
Standard.

Q18:

A:
I
currently
provide
a
large
amount
of
permitting
data
to
EPA
from
my
State
(
or
Tribal
or
local
governmental)
agency.
What
does
the
Permitting
Data
Standard
mean
for
that
exchange?
In
the
short
term,
probably
very
little.
However,
as
States
and
EPA
modernize
their
systems
and
work
towards
improved
and
integrated
data
exchange
tools
(
see
"
Network"
Question,
below)
this
Data
Standard
will
be
used
as
the
basis
for
new
data
exchanges.
State
and
EPA
data
flows
are
governed
by
a
complex
set
of
mandates
and
agreements
that
this
Data
Standard
will
not
change.
Instead,
this
Data
Standard
is
intended
to
serve
as
a
tool
to
better
facilitate
State
and
EPA
data
flows.
As
EPA
implements
this
Data
Standard
it
will
influence
the
data
EPA
seeks
from
States
and
the
way
in
which
those
data
are
to
be
transmitted.

Q19:

A:
What
does
this
standard
have
to
do
with
the
Exchange
Network?
I
thought
everything
was
supposed
to
be
in
XML.
Is
this
XML?
The
Network
concept
relies
upon
common
"
Data
Exchange
Templates"
(
DETs)
expressed
in
"
XML,"
and
exchanged
based
on
common
protocols.
This
Data
Standard
would
be
used
as
the
starting
point
or
"
core"
contents
for
DETs
that
contain
permit
information.
Once
established
and
approved,
these
flows
would
replace
existing
feeds
to
EPA's
national
data
systems.
For
example,
several
states
have
used
a
DET
based
on
the
State/
EPA
Facility
Identification
Standard
to
exchange
facility
data
with
EPA
and
other
States,
using
N
and
will
be
available
Data
Standard.

If
the
data
elements
in
the
Permitting
Data
Standard
don't
fit
my
program,
but
I
have
to
use
it
rotocols.
The
XML
expression
of
this
Data
Standard
is
under
development
.
From
that
point
forward,
a
new
DET
for
Permit
would
be
based
on
this
Q20:

4
confusion?
A:

e
levels,
and
the
team
ensure
that
this
standard
is
useful
and
provides
Use
of
the
Data
Standard:

Q21:
A:
Who
will
use
the
Permitting
Data
Standard?
All
Federal,
State,
Tribal
and
local
government
agencies
involved
in
issuing
or
managing
environmental
permits
or
authorizations,
or
who
manage
permitting
data,
are
encouraged
to
use
the
Permitting
Data
Standard
when
and
if
they
share
or
exchange
data
with
other
agencies.
They
are
also
encouraged
to
refer
Data
Standard
and
use
it
as
a
tool,
if
they
are
planning
to
update
or
enhance
their
own
ms.
The
public
will
be
the
ultimate
user
of
the
Data
Standard
because
it
will
promote
data
in
which
they
are
interested
and
that
they
request
through
data
queries,
etc.

Q22:
A:
Will
EPA
be
issuing
rules
for
use
of
the
Permitting
Data
Standard?
No,
at
least
not
in
the
sense
of
issuing
formal
regulations.
Information
on
the
standard
will
be
available
through
the
EDSC
website
and
the
Environmental
Data
Registry
(
EDR).

Will
the
Permitting
Data
Standard
be
open
for
revision
in
the
future?
How
will
the
Standard
be
maintained?
Yes.
There
is
every
reason
to
expect
that
future
adjustments
or
revisions
will
be
necessary.
The
need
for
revisions
may
arise
in
at
least
two
areas:
(
1)
Environmental
programs
evolve,
and
new
programs
may
be
added.
This
will
necessitate,
at
a
minimum,
revisions
and
additions
to
the
lists
of
Permissible
Values
associated
with
certain
data
elements.
(
2)
Once
in
use,
we
may
discover
flaws
in
the
Data
Standard
that
need
to
be
corrected
(
e.
g.,
linkages
and
relationships
that
need
to
be
adjusted;
additional
levels
of
detail
that
should
be
provided,
etc.)
EPA
and
ECOS
expect
to
maintain
an
ongoing
institutional
mechanism
to
make
needed
future
revisions.
Q23:

A:

Technical
Questions
 or
Implementers:

Q24:

A:
Why
isn't
the
Permit
Numberndentifier
sufficient
to
identify
a
permit
uniquely?
Why
does
this
matter?
Unique
identification
of
a
permit
is
important
because
it
allows
one
permit
to
be
positively
identified
and
distinguished
from
all
others
(
even
those
that
may
have
similar
names,
etc.)
One
of
the
objectives
of
this
Permitting
Data
Standard
is
to
provide
a
means
of
uniquely
identifying
permits
across
agencies,
programs
and
levels
of
government,
so
that
information
can
be
exchanged
without
confusion.
Permit
identifiers
issued
by
permitting
agencies
are
typically
unique
within
a
program,
but
not
necessarily
within
an
agency.
There
is
typically
no
assurance
that
one
state's
identifying
numbers
are
different
from
another's.
For
this
reason,
the
EPA
Business
Rules,
which
represent
a
specific
Agency
implementation
of
the
Standard,
specify
a
combination
of
data
elements
(
Permit
Numberhde
Organization
and
Permit
Type)
that
will
provide
unique
identification
Q25:
A:
Do
all
permits
have
"
permitted
features?"
The
permitted
feature
group
of
data
elements
includes
information
about
a
permitted
feature
of
a
permit.
Most`
permitted
entities
will
have
at
1
outfall.
The
standard
also
allows
le
permitted
features
for
more
complex
facilities.
In
some
cases,
a
facility
(
or
other
permitted
entity)
may
have
no
specific
permitted
features
but
nevertheless
be
ne
"
permitted
feature,"
such
as
a
stack,
storage
unit,
or
5
subject
to
general
re
practices.
In
such
a
Do
we
need
to
use
the
Permissible
Values
from
the
Data
Standard?
ements
such
as
reporting,
personnel
training,
,
the
standard
allows
the
flexibility
not
to
spec1
­
wide
best
management
permitted
features.

Q26:
A:
s,
and
text
that
can
be
used
in
exchanging
permissible
values
(
e.
g.,
Part
A),
agencies
using
iate­
even
if
the
a
Q27:

A:
What
if
I
wish
to
exchange
information
that
isn't
covered
by
the
listed
Permissible
Values?
Does
ieves
that
the
Permitting
Data
Standard
will
be
appropriate
for
exchanging
range
of
permits,
licenses
and
authorizations
at
the
Federal,
State,
Tribal
and
The
Team
developed
proposed
Permissible
Values
for
widely
used
major
er
Federal
environmental
laws.
The
Team
anticipates
that
users
exchanging
s
beyond
those
listed
will
work
out
additional
permissible
values
in
the
hanges
among
specific
data
exchange
partners.
The
Team
is
interested
in
of
such
a
"
partially
managed"
set
of
permissible
values.
The
Team
also
be
desirable
to
develop
more
extensive
lists
of
permissible
values
es
such
as
solid
waste
landfill
permits
common
to
many
state,
tribal
Q28:

A:
This
Standard
Do
data
elements
in
our
application
systems
need
to
be
the
same
data
type
as
the
Standard
Data
Element?
What
i
At
times,
differences
between
system
parameters
and
Data
Standard
specifications
may
require
some
translation
from
accommodate
th
conducted
to
date.
If
a
system
has
a
longer
value
for
a
given
element
and
the
organization
wishes
to
exchange
data
using
the
standard,
the
value
exported
from
the
system
would
have
to
be
adjusted
(
e.
g.
truncated
or
abbreviated).
Field
lengths
in
the
standard
can
be
increased
if
partner
needs
require
this,
through
the
maintenance
review
of
the
standard.
Data
Element
field
lengths
are
longer
or
shorter
than
the
standard?
ifies
how
information
will
be
exchanged,
not
how
systems
should
be
designed.

that
uses
field
lengths,
etc.
Field
lengths
in
the
standard
are
intended
to
ted
maximum
length
of
the
values
across
partner
systems
based
on
analysis
Q29:

A:
Does
the
draft
standard
allow
the
tracking
of
off­
site
waste
disposal
that
may
be
generated
by
a
permitted
entity?
Yes.
The
draft
standard
provides
for
this
by
first
identifying
the
substance
(
e.
g.,
sludge)
or
other
material
by
using
the
FaciZity/
Feature
Characteristic
Name.
How
the
permitted
facility
manages
that
material
(
e.
g.,
land
application)
can
be
indicated
by
using
Methodology
Type.
Capturing
the
off­
site
location
of
the
land
application
can
be
done
by
using
Methodology
Description,
which
is
sufficiently
flexible
with
a
complementary
format
that
is
large
enough
to
allow
location
descriptions.
However,
the
Latitudenongitude
Data
Standard
should
be
used
for
defming
point
locations,
and
the
Facilitj?
Zdentijication
Data
Standard
should
be
used
if
applicable.
,

6
