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."
"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."
"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."
"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
"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."
"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."
"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."
"Very informative site! A useful tool for anyone in the environmental
"This site is very important to our environment. Please keep
the data permanently available to the public. Thank you."
"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."
"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
"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."
"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."
"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."
"...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"?"
"...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
"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."
"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
"The following is a bulleted list of proposed comments and
suggestions regarding the Enforcement and Compliance History Online
("ECHO") public database.
"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
"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."
"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."
"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."
"...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."
"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."
"...Your site is well designed and easy to navigate with a
lot of different search tools..."
"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.
"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."
"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."
"[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."
"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."
"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."
"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."
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.
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