Understand common ECHO issues

The EPA's Enforcement and Compliance History Online (ECHO) database is valuable for understanding the environmental compliance status of regulated facilities. However, users should be aware of some common compliance issues and data limitations when interpreting ECHO data. This article will provide an overview of these issues and help you navigate the complexities of ECHO compliance data.

ECHO data is based on information reported by regulated facilities to EPA and state, local, and tribal environmental agencies. The completeness of this data can vary depending on the type of facility and the reporting requirements for each environmental program.

In general, data completeness is higher for larger facilities, such as:

• Clean Air Act (CAA) active, "federally-reportable" sources

• Clean Water Act (CWA) active, "major" permittees

• Resource Conservation and Recovery Act (RCRA) operating treatment, storage, and disposal facilities and active large quantity generators

Data for smaller facilities may be less complete or not reported at all, as some states do not require smaller facilities to report certain data to EPA. To better understand the variability in reporting requirements, see the Data Entry Requirements matrix on the ECHO website.

ECHO data represents a snapshot of the information available in the source databases at the time of data extraction. There is typically a lag time between when data is entered into the source database and when it appears in ECHO, ranging from a few weeks to a few months. While Encamp's Insights data is updated on a weekly basis to mirror ECHO, this means that Insights data may not always reflect the most current compliance status of a facility.

While EPA and state agencies work to ensure the accuracy of the data in ECHO, there are still some known data problems that users should be aware of when interpreting compliance information.

Some of the most notable issues include:

1. Resource Conservation and Recovery Act (RCRA):

   • Some facilities that no longer handle hazardous waste may still be listed as "active" in ECHO, as there is no regulatory requirement for these facilities to notify EPA when they cease hazardous waste activities.

2. Clean Air Act (CAA):

   • Some states, such as New York, report most of their Full Compliance Evaluations (FCEs) at the end of the fiscal year, which may not reflect the actual inspection dates.

   • In some EPA Region 3 states (Delaware, Virginia, West Virginia), some pH violations may be incorrectly reported due to differences in how pH limits are expressed in permits.

3. Clean Water Act (CWA):

   • The availability of penalty data and violation data may be limited for some facilities due to differences in reporting requirements before the 2015 NPDES Electronic Reporting Rule.

   • Locational data (latitude and longitude) may be missing for some facilities

   • The full universe of NPDES regulated facilities may not be available in ECHO until the 2015 NPDES Electronic Reporting Rule is fully implemented by the end of 2025.

For a complete list of known data problems, visit the ECHO Known Data Problems page.

Despite the known issues, EPA and state agencies have processes in place to ensure the overall quality of the data in ECHO. These include:

• Routine data quality checks and error correction processes

• Periodic data verification and validation by EPA and state agencies

• Opportunities for regulated facilities to review and correct their data through the ECHO error reporting process

When interpreting ECHO data, organizations need to consider the potential limitations and use the data in conjunction with other available information sources, such as facility-specific records or state environmental agency databases.