Reader Comment – 11-10-13 – Texas Tier II Reporting

This morning Daryl Spiewak left an informative response to my blog about deficiencies in reporting the actual locations of Tier II and Tier III facilities. He clarifies that Texas rules require facilities to provide street addresses or latitude and longitude information when they report Tier II and Tier III facilities.

Reporting Requirements

According to the EPA’s Emergency Planning and Community Right-to-Know Act (EPCRA) web site, Texas requires the use of the EPA’s Tier2 Submission software to prepare Tier II reports. That software (the 2012 version that was current as of Saturday’s download) does contain separate latitude – longitude entry blanks on the ‘Locataion & ID’ tab, so providing that information is no more difficult than adding the street address. That form tab also provides links to the on-line instructions for determining the latitude – longitude of a facility (though the Google Maps instructions no longer work).

The ‘State Fields’ tab does not include any statement that the latitude and longitude are required for submissions in Texas where there is not a street address available. So if a submitting facility is not familiar with the details of the Texas rules, they will not know that they are required to submit the latitude and longitude information. And any compliance specialist will always tell you to never provide more information than is required. The Verizon-MCI submission that I described in my post certainly seems to have followed that general advice.

Quality Control

The whole point of Michael Jacoby’s crusade and my post is that too much of the information in the Tier II reporting database is incorrect. I doubt that much of that inaccurate information is deliberate; scofflaws will just fail to report. So what is needed is quality control checks of the submitted data.

The first and easiest form of quality control is to validate data entry with value checking. The most obvious example is only allowing digital inputs in the latitude and longitude blocks that would be within a reasonable range for the city and state listed on the address tab of the form. There is currently no data validation for these entries.

Another way to verify the location data was entered properly would be to tie the registration page to a GIS application that would show the location provided either on the address page or the latitude – longitude page. This would allow the submitter to certify that the GIS properly displays the facility location.

Of course the best form of data validation is ground checking the information. The EPA certainly doesn’t have the funds or manpower to do this validation, nor do I expect that their State counterparts are any better funded or staffed. No the organizations that are best suited for ground checking the data are the people for whom the data is being collected, the local first responders. Unfortunately, the EPA cannot mandate that the local fire department physically check the location data provided in the Tier II data.

Emergency Response

Now if I were the head of a local fire department, it would be one of my highest priorities to ensure that my folks were well aware of any facility that reported that it had significant quantities of any chemical covered under the Tier II reporting requirements. At the very least I would want people to know in advance what facilities had these chemicals on site. Thus I would require, at the very least, that each of my engine companies at least drove by every location in their primary response area on a routine basis (monthly or quarterly depending on the size of the covered area and the number of sites). Doing this would provide a chance to ground check every reported facility location.

Even better would be for the current Local Emergency Planning Committee requirements to be expanded to include maintaining a list of verified Tier II facilities within their area of responsibilities. Knowing which facilities have these chemicals on-site is certainly a prerequisite for adequately planning for emergency responses to these locations.