How New National Air Data System Affects ECHO Data Display

The Enforcement and Compliance History Online (ECHO) website is displaying Clean Air Act stationary source data from the modernized national data management system, ICIS-Air. The old system, AFS, was retired in October 2014. Differences between the two systems, as well as new Agency violation policies affects the way some data are displayed on ECHO. Answers to frequently asked questions about the data system transition are presented below:

How is ECHO handling the transition from AFS data to the new ICIS-Air data?

AFS was shut-down and frozen as of October 17, 2014, and all compliance data was migrated to ICIS-Air. ECHO has switched its reports to pull ICIS-Air data. ICIS-Air is now the database of record. ECHO compliance data after October 17, 2014, are provided by the ICIS-Air data system and will be displayed to be consistent with the way information is currently recorded. Air compliance status data in ECHO for periods prior to October 17, 2014 reflect what was in the AFS system at the time of the data freeze. The AFS compliance status data will be included in ECHO until it rolls off the three-year display window.  As noted in more detail below, ECHO will display violations reported into the new ICIS-Air data system on the date that the agency made the determination that a violation occurred or, if no date was provided by the agency, the date it was reported as a violation to ICIS-Air.  In ICIS-Air, violations are reported on a Case File and the earliest Federally Reportable Violation (FRV) Determination Date is captured on the Case File record and displayed in ECHO.

How are violations shown in ECHO for the Clean Air Act, and is there a change between the old system (AFS) and the new system (ICIS-Air)?

There has been a change in how noncompliance and violations are shown in ECHO due to the modernization of AFS into ICIS-Air.  In the old system (AFS), EPA and state and local agencies used a “compliance status” field for each facility when entering violations.  On a monthly basis, EPA would take a “snapshot” to identify whether facilities had a violating compliance status.  ECHO would show the facility as being in noncompliance during each quarter that the facility had a violating compliance status.  ECHO’s reports would show the facility in noncompliance starting in the first quarter when violation status occurred.  The facility would continue in noncompliance until the violating compliance status was changed in AFS.

In the new ICIS-Air system, EPA and state, local, tribal and territorial agencies (collectively called "enforcement agencies") are entering a violation on the date that the violation determination is made. If no determination date is reported by the agency, ICIS-Air defaults the determination date to the date it is reported. ECHO will show that violation ONLY in the quarter the violation determination was made or reported. While ECHO does not display the duration of violations, some state/local agencies may have more information about the duration of the violations listed in ECHO. If a violation is determined to be a High Priority Violation (HPV), ECHO will show that the facility has an enforcement action ongoing for an HPV until the enforcement process is (addressed or resolved). An indication that a source has an HPV enforcement action does not indicate that the violation is still ongoing. Enforcement agencies can elect to report the dates the violation actually ends, but are not required to do so.

Can the old AFS compliance data shown in ECHO be changed, and how can errors be corrected?

As the old AFS compliance data are frozen, it is not possible to directly modify the AFS data. However, errors in the AFS data can be reported using the error reporting feature in ECHO, see How to Report an Error. Data errors reported in this manner will be flagged as appropriate on the detailed facility reports.

Was all the old AFS data migrated to the new ICIS-Air system?

Most of the data in AFS were migrated to ICIS-Air, including all compliance monitoring and enforcement history. However, due to differences in how ICIS-Air tracks compliance status, ECHO is no longer able to take compliance status snapshots. The snapshots have been replaced by entering a violation on the date that the violation was discovered.

What happens to facilities that had long-standing noncompliance in the old system (AFS) – what duration of noncompliance is shown in ECHO? [Note that this question applies to violations, not high priority violations]

Facilities with longstanding noncompliance in the frozen AFS data (prior to October 17, 2014) will retain the noncompliance designation for the time period prior to the ICIS-Air launch until data rolls off ECHO three-year window.

How are High Priority Violations (HPVs) tracked in the new database, and is there a change from the old system?

EPA will continue to track facilities that have enforcement actions involving HPVs in ICIS-Air similarly to how they were tracked in AFS. However, just prior to the changeover from AFS to ICIS-Air, EPA issued on August 25, 2014, a revised enforcement response policy for HPVs. The criteria to be used for determining whether a FRV is an HPV has been changed to reflect a subset of CAA violations that EPA feels warrant additional oversight. EPA expects that as a result of this change, fewer identified violations will meet the HPV criteria. It is important to note that ICIS-Air, like AFS, tracks the enforcement action involving the HPV. If ECHO shows that a facility has an HPV, it does not mean that the violation is on-going, rather that the enforcement action is still ongoing.

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Is there any change to ECHO’s public release of High Priority Violations identified by state and local governments?

In the old AFS system, once the state, local, or tribal agency entered the determination that the violation met the definition of High Priority Violation, ECHO would show that HPV. However, consistent with EPA policy, ICIS-Air has been developed to allow agencies to designate information about HPVs as enforcement sensitive until they are linked to a public document such as a notice of violation or the agency otherwise determines the HPV determination can be made public.

Is there a change in what violations have to be reported between the old and new system?

The switch from AFS to ICIS-Air in itself did not mandate any changes to which violations are reported. However, EPA made significant changes to the HPV enforcement response policy and Federally-Reportable Violations (FRV) policy. ICIS-Air was implemented to be consistent with the changes to the new policies. In general, EPA revised the HPV Policy to address a subset of CAA violations that warrant additional oversight by EPA. The FRV Policy was streamlined to emphasize reporting of violations that are most important to EPA. As a result, EPA expects a smaller number of HPVs and FRVs to be reported with greater accuracy.

Did ECHO change its map display regarding facilities that have not been evaluated under expected time frames? (Previously, ECHO showed facilities with an “unknown” status in gray and facilities with recent full compliance evaluations and no violations as blue.)

ICIS-Air, and thus ECHO, does not distinguish facilities with an "unknown" status (those that did not meet compliance evaluation frequency goals) from those with no recent violations.

Are the State Dashboards and Comparative Maps up to date with the ICIS-Air data that are shown in ECHO?

No. Once new measures consistent with the new HPV enforcement response policy and FRV guidance are programmed, the State Dashboards and Comparative Maps will be updated with fiscal year 2015 data from ICIS-Air.  Data from fiscal year 2014 and before are from AFS, are frozen, and will not change.

Have all state and local agencies transitioned to using ICIS-Air?

Yes, as of the launch of the ICIS-Air data in ECHO, not all state and local agencies are actively transferring new data to ICIS-Air.  Many agencies do not report data directly to the ICIS-Air application but instead provide information electronically to EPA via the Exchange Network. These agencies needed time to configure their data transfer capabilities to line up with the new ICIS-Air structure. A listing of agencies that are still working on this is available at the ECHO Known Data Problems page. Their data are shown as migrated from AFS in October 2014.

How does ECHO define “recent violations” for users searching or mapping facilities?

Recent violations include: (1) all unresolved enforcement actions involving HPVs; and (2) any FRVs with a determination date in the last four quarters. "Unresolved" means that the enforcement action is not concluded; it does not necessarily mean that the violation is still ongoing. Enforcement agencies can elect to report the dates the violation actually ends, but are not required to do so. EPA no longer tracks compliance status for FRVs, so the "recent violations" search instead uses the FRV determination date.

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