[April 19, 2002] The US Environmental Protection Agency's Central Data Exchange supports reporting via XML-based submissions for critical information on air, water, waste, and toxic substances. Together with the National Environmental Information Exchange Network and state initiatives, EPA is establishing secure points of exchange or 'nodes' for collection and distribution of environmental data.

The Central Data Exchange "serves as the single point of entry for many environmental data submissions to the Agency. CDX is designed to be EPA's Node on the National Environmental Information Exchange Network (NEIN) which will link EPA and the states over the Internet and will also eventually include other stakeholders. EPA is working closely with reporting entities, States and Tribes to enable the electronic submission of data via the Internet. The Central Data Exchange Team is responsible for: <1) Developing the technical capabilities to receive and process electronic reports; (2) Developing an appropriate policy and legal framework to ensure that electronic submissions are legally acceptable; and (3) Working with States, Tribes and reporting entities on electronic reporting. CDX is receiving submissions in a variety of formats, including user-defined flat files, Extensible Markup Language (XML), and Web forms submitted over the Internet."

CDX "provides production data flows for the Toxic Release Inventory (TRI), National Air Emissions Inventory (NEI), and Unregulated Contaminant Monitoring Rule (UCMR). Several others including Interim Data Exchange Format (IDEF) for the Permit Compliance System (PCS), submissions under the Toxic Substance Control Act (TSCA) and the Resource Conservation and Recovery Act (RCRA), [Safe Drinking Water Accession and Review System (SDWARS)] are in development."

"The Central Data Exchange concept has been defined as a central point which supplements EPA reporting systems by performing new and existing functions for receiving legally acceptable data in various formats, including consolidated and integrated data."

"The most common CDX translation at this time is to accept XML formats in from users and translate them into flat-files acceptable to the EPA legacy systems. The CDX can accept a variety of formats including program office specific flat-files, EDI, and XML. XML is the preferred NEIN format for input."

The CDX Implementation Guidelines (IG) for UCMR explain the methods of interacting with SDWARS through CDX The EPA's UCMR XML application is presented in "EPA Implementation Guidelines for SDWARS/UCMR. Volume IV: XML Format." It "documents the specifications for submitting data for the Unregulated Contaminant Monitoring Rule (UCMR) program to the U.S. Environmental Protection Agency (EPA) using Extensible Markup Language (XML) standards. Only laboratories that are registered with EPA's Central Data Exchange (CDX) can submit data to the Safe Drinking Water Accession and Review System/UCMR (SDWARS/UCMR), the information system that supports the collection of data for the UCMR." Appendix A provides the UCMR XML DTD, Version 2.1. Appendix B supplies a UCMR File Structure Tree Diagram. Appendix C contains the UCMR Data Dictionary: XML DTD, Version 2.1. Appendix D provides an UCMR XML Instance (an example XML file based on the UCMR XML DTD, Version 2.1).

The CDX SDWARS/UCMR reporting system allows laboratories "three options for submitting UCMR monitoring results. These include submitting the data by hand using Web forms, or through one of two types of electronic file transfers: extensible mark-up language (XML) files or formatted flat files. XML files are based upon a document type definition (DTD) that defines the rules the XML document must follow to be valid according to the UCMR Reporting Implementation Guidance, Volume IV... Because of the complexity of implementing XML, an organization should possess qualified information technology staff, sufficient electronic traffic, and a substantial environmental reporting obligation. Regardless of the nature of the obligation, it must be sufficient enough that the organization is willing to invest resources in collecting and managing environmental data." [EPA 815-N-02-002a, February 2002]

NEIEN (National Environmental Information Exchange Network) and data flow projects: The goal of NEIEN "is to foster standardization and information sharing among States and Tribes. Common to all NEIEN partners is the need to establish secure points of exchange or 'nodes'. CDX is EPA's Agency node. EPA, in partnership with the NEIEN members, has identified and prioritized network data flows for inclusion in the deployment and implementation of CDX and State nodes."

EPA/CDX Data Flow Projects include:

• Facility Registry System (FRS) "provides Internet access to a single source of comprehensive information on facilities subject to environmental regulations or of particular environmental interest. The Facility Registry System (FRS) is a centrally managed database that has been developed by EPA's office of Environmental Information (OEI). It identifies facilities subject to environmental regulations or of environmental interest and provides Internet access to a single source of comprehensive information. The FRS has high quality, accurate, and authoritative facility identification records which are quality assured through rigorous verification and management procedures that incorporate information from program national systems, state master facility records, data collected from EPA central receiving registrations and data management personnel. As of February 22, 2002, FRS had over 753,000 unique facility records linking to over 1,002,000 program interests. As of February 2002, CDX and FRS are working with six (6) state partners engaged in the exchange of FRS data. See the State/EPA XML Format Specification, Version 2.0, including Facility Identification XML Schema and XML element types.
• Environmental Data Registry. "XML tags will be established for all EPA standard data elements. [As of 2002-04] a draft set of XML tags for the data elements included the final EPA data standards is under review. These tags will be registered in the EDR as alternate names for the data elements and can be found on the data element detail page for each of the EPA data standards. An XML tag name will be identified with the Name Context of 'Draft XML tag.' The XML tags proposed for standard data elements are draft and subject to further development. Those using these tags should be sure to deploy them in systems and business processes that can be readily changed or modified to reflect the evolution of the data element tag formation conventions.
• National Emission Inventory (NEI), a "Clean Air Act (CAA) collection of point, area, mobile, and biogenic emissions data periodically submitted to EPA's Office of Air and Radiation by State and local air programs."
• Resource Conservation and Recovery Act Information (RCRAInfo), which "supports the transmission of State hazardous waste data to EPA using standardized flat file formats. CDX is developing the option to support flat and XML formats and promote information sharing among State nodes."
• Storage and Retrieval System (STORET), a "repository for water quality, biological, and physical data and is used by state environmental agencies, EPA and other federal agencies, universities, private citizens, and others . The current [2002-02] NEIEN effort has focused on developing an XML schema for STORET exchanges."
• Permit Compliance System (PCS)/Interim Data Exchange Format (IDEF) "is a data exchange format based on Extensible Markup Language (XML). States choosing to adopt the IDEF XML Format can implement PCS exchanges through CDX to PCS.
• Air Quality Sub-system (AQS) "contains measurements of ambient concentrations of air pollutants and associated meteorological data. The data is collected by thousands of monitoring stations operated by EPA, national, state and local agencies. EPA intends to partner with a limited number of interested reporting entities to pilot an information sharing and submission process using CDX. This includes web form submissions and XML file transfers of ambient air monitoring data to and from EPA, States, Tribes and localites."
• Discharge Monitoring Reports (DMRs) "are filed on a regular basis by major and minor permittees operating under the National Pollution Discharge Elimination System. States are currently working on plans to design and test an XML format for the receipt of Electronic DMRs from industry."
• Toxics Release Inventory (TRI) "is a publicly accessible online database of facility specific releases for over 600 toxic chemicals. CDX supports the electronic receipt of TRI Form R submissions from the regulated industry."

Proposed rule for electronic reporting. From: "Establishment of Electronic Reporting: Electronic Records. Proposed Rule" August 31, 2001. From the Federal Register: August 31, 2001 (Volume 66, Number 170).

EPA is proposing to allow electronic reporting to EPA by permitting the use of electronic document receiving systems to receive electronic documents in satisfaction of certain document submission requirements in EPA's regulations. The proposal also sets forth the conditions under which EPA will allow an electronic record to satisfy federal environmental recordkeeping requirements in EPA's regulations. The submission and storage of electronic documents in lieu of paper documents can (1) Reduce the cost for both sender and recipient; (2) Improve data quality by automating quality control functions and eliminating rekeying, and (3) Greatly improve the speed and ease with which the data can be accessed by all who needed to use it."

With respect to the electronic document submission process and criteria addressed by today's proposal, we intend CDX functions to include:

• Access management -- allowing or denying an entity access to CDX
• Data interchange -- accepting and returning data via various of file transfer mechanisms
• Signature/certification management -- providing devices and required scenarios for individuals to sign and certify what they submit
• Submitter and data authentication -- assuring that electronic signatures are valid and data is uncorrupted
• Transaction logging -- providing date, time, and source information for data received to establish 'chain of custody'
• Acknowledgment and provision of copy of record -- providing the submitter with confirmations of the data received
• Archiving -- placing files received and transmission logs into secure, long-term storage
• Error-checking -- flagging obvious errors in documents and document transactions, including duplicate documents and unauthorized submissions
• Translation and forwarding -- converting submitted documents into formats that will load to EPA databases, and forwarding them to the appropriate systems
• Outreach -- providing education and other customer services (such as user manuals, help desk) to CDX users

Costs and Benefits: The major elements include: the use of modern electronic technologies for the production, completion, signing, transmitting, and recording without the use of paper copies. Within the assessment of technologies we chose three forms of electronic reporting (web forms, EDI, and XML) that EPA's CDX plans to support. For those entities using web forms, the costs of reporting to EPA electronically would be negligible, as EPA intends to provide the web forms and signature capabilities needed. In the latter two approaches (EDI and XML), EPA anticipates additional up- front cost will be incurred by regulated entities to establish EDI or XML file generation capabilities, but the savings will be larger over time, as these entities can more fully automate their reporting to EPA...

EPA is exploring a number of standards-based approaches to Web forms, including electronic data exchange formats based upon the American National Standards Institute (ANSI) Accredited Standards Committee's (ASC) X12 for Electronic Data Interchange or EDI. EPA is also proposing Internet data exchange formats based on the Extensible Mark-up Language (XML) specifications developed by the World Wide Web Consortium (W3C). The World Wide Web Consortium, however, is not a voluntary consensus standards body within the meaning of the NTTAA, and EPA could not identify an applicable consensus standard for creating and transmitting data using XML. Therefore, EPA has decided to propose an XML data exchange format, referred to as a document type definition for Internet transmissions as an alternative to the ANSI ASC X12 formats that are customarily transmitted across Value Added Networks. It is possible that the ANSI ASC X12 standards body will develop standards for XML document definitions in the future, and EPA will monitor this situation as we develop a final rulemaking...

References:

• EPA CDX main website
• Central Data Exchange (CDX) reporting website
• Central Data Exchange Fact Sheet on XML
• "EPA Implementation Guidelines for SDWARS/UCMR. Volume IV: XML Format." Reference: EP001S4. EPA 816-R-01-022C. December 2001. 81 pages. With two DTDs and a sample XML instance. For general instructions on using XML, see "Volume I: Introduction to CDX and UCMR Submissions." [cache]
• UCMR XML Document Type Definition, Version 2.1
• Draft XML Tags for Data Elements Included in EPA Data Standards [cache]
• Facility Identification - State/EPA XML Format Specification Schema Representation (Version 2.0)
• Facility Identification XML Schema and XML element types listing. Cache schema, tags.
• Cross-Media Electronic Reporting and Record-keeping Rule (CROMERRR) Fact Sheet
• Getting Started With CDX
• Unregulated Contaminant Monitoring Regulation (UCMR)
• US Environmental Protection Agency (EPA)
• Minutes of Federal CIO Council XML Working Group. Wednesday, February 20, 2002. Mr. Steve Vineski of the EPA gave an account of EPA's XML policies.
• "Central Data Exchange for Air Emissions Inventory Data." By Lee Tooly (US EPA). In CHIEF Newsletter Volume XII, No. 1 (Winter 2001).
• Contact: David Schwarz or Evi Huffer