BIG DATA: A GAME CHANGER FOR

ENVIRONMENTAL MANAGERS, 

ADVOCATES AND REGULATORS?

Environmental Law Institute

October 22, 2013

Omni Shoreham Hotel

Alexandra Dapolito Dunn

Association of Clean Water Administrators
“Records analyzed by The Times indicate that

the Clean Water Act has been violated more

than 506,000 times since 2004, by more than

23,000 companies and other facilities, according

to reports submitted by polluters themselves.

Companies sometimes test what they are

dumping only once a quarter, so the actual

number of days when they broke the law is often

far higher. And some companies illegally avoid

reporting their emissions, say officials, so

infractions go unrecorded.”

http://www.nytimes.com/2009/09/13/us/13water.html?pagewanted=2

What does this mean for water quality? 
KEY TO SUCCESS = TIMELY, ACCURATE, 

COMPLETE DATA

• Improving data quality/quantity by 

creating new web-based data collection 

tools 

• Increasing data quality/quantity via tools 

that leverage the existence of the 

information in an electronic format 

• Using data to communicate and manage 

• Identifying performance metrics to show 

how the data leads to improved 

compliance rates, program efficacy, & 

environmental improvement
DATA FLOW IN THE FIELD

• 58% of respondent states use data-yielding 

technology as part of the inspection process:

• Hand-held devices, tablets, GPS, digital 

cameras, GIS tools, and field computers

• Monitors and airplane flyovers. 

• Standardized report forms with evaluation 

areas and a large pick list of common 

deficiencies 

• Improves data collection and transfer

• Promotes consistency between inspectors 

and a more certain process for facilities

• Increases ability of the state to effectively enforce the 

CWA as well as do more with limited inspection staff 
DATA FLOW FROM THE DESK

• 55% of respondent states utilize an eNOI* tool or 

other eApplication process

• 73% of respondent states use an eDMR/NetDMR tool

• Automated systems for sending 

notices for untimely submissions 

and permit limit violations

• Electronic forms = improvements in 

timeliness and accuracy of 

reporting, some resource savings, 

more informed regulated 

community 

• Compliance assistance via a click
MAKING DATA AVAILABLE TO THE PUBLIC

• 56% of states’ DMR data is available on a public 

website

• E.g., tracking applications, locating active 

permits, enforcement actions

• 31% of respondent states have a 

violations webpage 

• 56% have an electronic citizen complaint system

• 42% report using GIS for decision making, and 70% 

of those respondents make that data directly 

available to the public
MAKING DATA AVAILABLE TO MANAGERS

• 29% of respondents report prioritizing 

which facilities to monitor based on risk

• Generating data via incentives – participation 

encouraged via reductions in permit or annual fees; 

participation in electronic programs a condition of 

settlements; purchasing computers for the regulated 

community

• 66% of respondent states’ permits require 

experts or third parties to certify data in 

application for and in renewal of NPDES 

permits, enhancing efficiency 
• Resources 

• Measuring Success

• Prioritization

• Program Management 

• Program Oversight 

• Push vs. Pull

• Defining Transparency

• Burden Reductions Can Be Found

• Approaches to Data – What States 

& Federal Gov’t Need is Different

• Big Data and Really Big Data

• E.g., DMR monthly reporting

• E.g., annual CAFO report

• Historic data? E.g., CSOs, Major 

Sources