The External Data Framework (EDF) is a systematic, transparent, and voluntary process for individuals and organizations outside of IDEM to share the water quality data they collect on Indiana waters to IDEM’s Office of Water Quality (OWQ) for potential use in its programs. The EDF was developed to foster greater sharing of water quality data to assess, protect, and restore surface water resources throughout Indiana by IDEM and others.
Why would I want to share my data with IDEM?
The EDF can benefit your organization in several ways. For some organizations, having their data used by a state agency may help to ensure continued support for their monitoring efforts from funding institutions and the public. The EDF also provides data quality benchmarks that OWQ considers suitable for several local-level needs, which can be used to evaluate whether water quality data you have obtained from other sources are reliable for your own uses. Perhaps most importantly, the guidance and technical assistance the EDF provides can help you improve the quality of the data you collect:
- If your organization is in the process of developing a water quality monitoring study, the EDF will help you determine the quality control procedures you might need to ensure the data you collect are reliable for your intended use(s).
- If you are already monitoring, the EDF will help you identify any changes you might need to make in your monitoring program to improve the quality of your data, making it reliable for broader use by OWQ and other organizations.
- Adhering to EDF guidelines will help you produce a data set of known quality, enhancing both its credibility and value.
Are there any potential disadvantages to sharing my data with IDEM?
Participation in the EDF is voluntary. Because the EDF is administered by the Indiana Department of Environmental Management, all data submitted through the EDF is considered public information. Thus, by providing your water quality data to IDEM your data can be used by other organizations and individuals working to protect and restore Indiana waters.
If there are reasons you do not wish for your data to be made public, you need not participate in the EDF and are not required by IDEM to do so. Also, data submitted by external organizations will not be used by IDEM to initiate or support enforcement or otherwise negative actions against you or anyone else as an individual, organization or IDEM-permitted facility. IDEM has established policies and procedures in place to follow up on complaints about potential environmental issues and to conduct further investigation when necessary.
Why does IDEM want my data? Doesn’t IDEM collect its own data?
Indiana enjoys a wealth of water resources, and water quality monitoring is essential to their effective management. IDEM routinely monitors surface waters throughout the state. However, with more than 63,000 miles of streams and over 500 lakes and reservoirs, no single agency could possibly monitor every stream or lake.
Fortunately, there are many universities, municipalities, watershed groups and grassroots organizations throughout the state that participate in various water monitoring activities. And there are also several regulated facilities that conduct monitoring above and beyond what their permits require.
IDEM recognizes the value of water quality data available from other sources for more effective water resource management and has developed the EDF to make it easier for individuals and organizations interested in sharing their data with OWQ to do so.
How will my data be used?
The tiered structure of the EDF allows for data sets of varying quality. Each tier, which is based on the level of data quality associated with the data set, identifies several potential uses for which the data set is reliable. These uses are listed in Table 1 of the technical guidance for the EDF. The suitability of the data set for one or more of these uses depends on other use-specific requirements.
What criteria do I need to meet for IDEM to use my data to add/remove a waterbody from its 303(d) List of Impaired Waters?
Clean Water Act (CWA) Section 303(d) listing decisions are considered a Tier 3 use in the EDF. External data submitted for this use must meet Data Quality Assessment (DQA) Level 3 requirements for data quality and must be of the type and amount needed for 303(d) listing decision(s). These requirements are articulated in the technical guidance for the EDF.
Is there an appeals process if my data are not used?
No. OWQ is not required to use external data in its programs nor is there any appeals process in place to challenge OWQ’s decision not to do so. This being said, the EDF was developed to increase the amount of reliable external data available to OWQ programs for decision-making processes, not to limit it.
Most of OWQ’s decisions to limit the use of external data are the result of concerns regarding data quality. Where this is the case, participants are encouraged to contact the External Data Coordinator for technical assistance to help ensure they are meeting the data quality and other requirements for their EDF tier of interest.
Will IDEM use my data for regulatory purposes?
Generally, it is the policy of OWQ to use external data for any purpose, regulatory or non-regulatory, for which it has determined the data are reliable and suitable. OWQ’s regulatory uses are considered Tier 3 uses. If your data set is ranked as Data Quality Assessment (DQA) Level 3, it will be considered reliable for any OWQ Tier 3 use. Its suitability for a given use depends on additional use-specific requirements regarding the type of data needed, minimum data requirements, etc. The primary exceptions to OWQ’s general policy regarding the use of secondary data are in cases where there are conflicting data for the same waterbody and in potential enforcement cases.
In cases of conflicting data, OWQ will attempt to resolve the conflict and in so doing, will determine the most appropriate data set to use. Regarding enforcement, no data submitted through the EDF will be used by IDEM to initiate or support enforcement actions against permitted facilities. IDEM has processes in place to follow up on complaints about potential environmental issues and to conduct further investigation when necessary. In cases where external data submitted through the EDF indicates possible permit violations, IDEM will investigate as appropriate in accordance with established policies and procedures.
Can my data be used to prove that an entity is not abiding by its permit?
OWQ will not use any data submitted through the EDF to initiate or support enforcement actions against permitted facilities. OWQ’s Compliance and Enforcement Program and Watershed Assessment and Planning Branch work together and with and other relevant state and federal agencies to collect the data necessary to support enforcement activities. IDEM has processes in place to follow up on complaints about potential environmental issues and to conduct further investigation when necessary. In cases where external data submitted through the EDF indicates possible permit violations, IDEM will investigate as appropriate in accordance with established policies and procedures.
How do you know that the data you receive are credible?
All external data submitted to OWQ through the EDF are reviewed in accordance with OWQ’s data quality assessment process, which is based on the same system OWQ uses to verify and validate its own data for use in OWQ programs. This process reviews the quality assurance and other documentation provided with the data package to ensure it contains all the information needed to determine the quality of the data set (verification) and the individual results to identify any error and determine the analytical quality of the data set (validation). Based on OWQ’s data quality assessment, external data sets are assigned a data quality assessment level that indicates their reliability for one or more uses in the corresponding EDF tier.
I monitor my lake for the Indiana Clean Lakes Program. Do I need to submit my data through the EDF to have IDEM consider my data for use by its programs?
No. Individuals monitoring lakes and reservoirs for the Indiana Clean Lakes Program do not need to also participate in the EDF to have their data considered by OWQ for potential use in its programs. The Indiana Clean Lakes Program is administered by the Indiana University School of Public and Environmental Affairs with a grant from OWQ’s Nonpoint Source Program. Given this, volunteers that collect and submit water quality samples or results through either program can be confident that their data will be automatically considered by OWQ for potential uses in its programs.
A consultant conducts the monitoring for my organization. Does it matter whether the consultant provides our results or are we required to submit it ourselves?
The choice of who will enter the data your organization collects is yours. Anyone may submit water quality data to OWQ through the EDF, which does make it possible that a given data set might inadvertently be entered twice. OWQ’s internal processes are designed to identify duplicated data entry in most cases. However, OWQ recommends that the decision regarding who will enter the data collected on behalf of your organization be determined prior to submitting your data.
When should I submit my data?
Data can be submitted to OWQ through the EDF at any time. Participants interested in having their data considered for one or more specific OWQ uses should review the program-specific timelines recommended for data submittals.
How old can my data be?
The representativeness of a given data set depends on its intended use. For example, older data may be very useful for determining trends over time or identifying changes that have occurred in a waterbody. However, for the purposes of determining current water quality conditions, more recent data would be needed. Given the variety of uses outlined in the EDF and the potential value of your data to these uses, OWQ welcomes all water quality data you and your organization may have to share.
Questions?
If you or your organization is interested in learning more about the EDF and how to share your water quality data with IDEM’s Office of Water Quality, you are encouraged to contact OWQ’s External Data Coordinator. If you are monitoring as part of a NPS Program grant project, please contact the External Data Quality Assurance Manager with any questions regarding your options for data submittal. General and Technical Guidance for the Office of Water Quality External Data Framework documents are also available to provide more information on the EDF process.
External Data Coordinator
IDEM Office of Water Quality
100 North Senate Avenue
MC 65-44 Shadeland
Indianapolis, IN 46204-2251
(317) 308-3081; 800-451-6027 (toll free)
ExternalDataFramework@idem.in.gov