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III. TNRCC's Current Situation

The following sections describe the major features of TNRCC's information management systems and highlight challenges that TNRCC faces to meet its future information needs. The discussion is organized as follows:


TNRCC's Inheritance

TNRCC's history has significantly influenced the characteristics of its information management infrastructure and the challenges it now faces to adequately meet its information needs well into the future. TNRCC's inheritance is two-fold, being both the product of a marriage of three former agencies, and being an environmental agency.

TNRCC was formed in 1993 by combining programs from three other Texas agencies--the Department of Health, the Air Control Board, and the Water Development Board. Many of TNRCC's official databases are "legacy systems" that were developed to support programs previously located in these other agencies. For example, the Municipal Solid Waste program relies upon databases that were developed when MSW was still part of the Department of Health. TNRCC as a result inherited various different systems on different technical platforms, few or none of which could connect and talk to one another. It naturally has taken time and significant investment to begin to standardize the technical infrastructure and then be in a position to better standardize and integrate the information itself.

As an environmental agency, TNRCC faces such challenges anyway. Environmental agency information systems traditionally have been driven by single-media regulatory requirements. Media-specific legislation spawns media-specific regulatory programs, which spawn program-specific information requirements and systems. EPA has a series of program-specific systems to which states must supply information; many states end up simply using a version of an EPA system. Funding requirements reinforce the program-specific systems: funding sources established for one program typically can be spent only to support that program, so broader systems efforts are hard to fund. The basic framework imposed by national environmental legislation and regulation, as passed on to states by EPA, thus complicates TNRCC's efforts to better integrate its information to meet its evolving needs.


TNRCC's Progress

Particularly within the last two years, TNRCC has made significant investments to overcome some of the challenges imposed by its history and inheritance. The Information Resources Division (IRD) has implemented a unified network infrastructure to enable information exchange and communications by all TNRCC staff across the agency. This foundation provides a powerful base for future efforts to provide broad access to information for TNRCC employees. IRD also has developed service agreements intended to better define the responsibilities and procedures for system and infrastructure maintenance, to ensure that IRD staff resources can manage the programs' support needs. TNRCC also has invested in the tools and training needed to enable TNRCC programs to develop information systems in a standardized way that can enhance opportunities for information sharing and interfaces among systems and programs.

At the strategic level, TNRCC has created an organizational framework designed to help it identify and address agency information needs. The IT Steering Committee has been created to provide senior management consideration of and decision-making regarding information needs and investments within the agency. Consisting of the Deputy Executive Director and the Deputies for each of TNRCC's Offices, the IT Steering Committee last year undertook a first-time priority-setting process that was intended to strategically assess needed information improvements across the agency and to prioritize funding allocations accordingly. The IT Steering Committee is staffed by an IT Work Group, which has a designated staff person from each major agency Office. The IT Work Group helps to identify emerging needs at the program level and brings those needs to the Steering Committee for consideration and decision-making. Through the efforts of the Steering Committee and the Work Group, TNRCC over the last 18 months has established a cross-program, cross-media dialogue on and recognition of information management needs and issues. This has been an important element in TNRCC's growth, from a collection of assembled regulatory programs drawn from other agencies, to a unified agency with a common mission and shared needs and priorities. This ISP is the most recent and concrete manifestation of TNRCC's efforts to continuously improve information management needs identification and decision-making.


Current Information Systems

TNRCC's information management systems can be divided into two groups: "official" agency systems that are known to be the official repository for certain types of data, and "unofficial" systems that have emerged to support specific needs of programs or individuals but that were not designed by the agency to be an official "home" for a set of data.

"Official" agency systems generally fall into one of five types:

"Unofficial" systems can be divided into two types:

"Official" Systems

Omnibus Program/Media-Specific Systems

Omnibus Program/Media-Specific Systems are major systems designed to support numerous agency functions surrounding a particular program or medium (such as hazardous waste, public drinking water systems, or wastewater dischargers). These systems are critical to the agency because they:

The primary examples of Omnibus Systems include:

Major Media-Specific Ambient Systems

TNRCC also maintains several mission critical systems that support program activities by providing information on ambient conditions (non source-specific background levels of air pollution or water pollution, or basic water-body or airshed characteristics). Examples of these systems include:

Supporting Program-Specific Systems

TNRCC has several systems that either complement the major "omnibus" databases or that collectively support a program's overall information management needs. Some programs that rely heavily upon a single, fairly limited legacy system develop additional supporting systems to provide them with more complete information management support. Programs have also developed complementary databases to support a specific, narrow program function.

Function-Specific Systems

Function-specific systems have been designed to support a targeted range of specific agency functions that may cut across many regulated universes. Some centralized databases support program functions:

Administrative Support Systems

TNRCC maintains several systems to support the management and administration activities associated with the routine operation of a state agency. These include budgeting, human resources, time accounting, and fee calculation databases.

Unofficial Systems

Shadow Systems

Many personnel duplicate information contained in an official agency system by entering it into private spreadsheets or local databases. Staff may create a shadow system to maintain closer oversight and control of data quality and completeness and to provide for easy and timely data retrieval. Shadow systems therefore are most likely to be created by staff who find it difficult to access, navigate, or retrieve data from a central agency system or because they believe quality of data in a central system is low. For example, program staff in one regional office maintained inspection-related activity information in a local database because it is easier to access, provides a more user-friendly reporting interface, and because data in the central system is based on paper copies of inspection reports that have been routed to the Central Office and entered into the system. The time lag and high risk of lost inspection reports associated with this procedure makes the central system of little use to regional staff.

Office/Personal Databases

Many regions and/or individual staff also create databases which contain information not covered by any agency system either to meet their individual operational needs or in anticipation of providing information that TNRCC's central office or other external parties might request (e.g., miscellaneous staff activity tracking data).

By their nature, unofficial systems generally are not inventoried or supported at an agency level, although IR staff may provide ad hoc software support to users.


Gaps and Barriers to Meeting Needs

Session participants believed that the poor accessibility and functionality of several TNRCC data systems sharply limited their ability to support routine agency functions such as permitting, compliance assurance, and enforcement. In addition, participants described an agency information management infrastructure that is highly fragmented, consisting of several "islands" of individual data systems completely separated from one another. The lack of linkages among systems seriously restricts TNRCC's ability to use collected information to address TNRCC's drivers by answering fundamental questions about how the agency operates, how it could operate better, and how well it is addressing environmental problems.

Several environmental agencies around the country have also recognized that their information management systems are often technically limited as well as highly fragmented. Agencies therefore are considering or undertaking initiatives to develop more integrated systems with improved functionality to better leverage their information resources. What these agencies and TNRCC should recognize, however, is that although system fragmentation is a significant problem, it is also a symptom of more serious, underlying conditions that, if left uncorrected, will erode agency investments in IT improvement and integration efforts.

The technical limitations and fragmented nature of the agency's major data systems create technical and organizational dynamics that reinforce and exacerbate the agency's information management problems. The following sections first identify the primary technical problems and then describe how they influence organizational dynamics to create a vicious circle.

Technical Problems

TNRCC faces three key technical problems that together create a vicious cycle of information system inadequacy. These are:

Highly Fragmented Island Systems

A key information management infrastructure problem is the highly fragmented nature of TNRCC's information management systems. System fragmentation reduces data quality and functionality and prevents the agency from fully utilizing the information that these systems contain.

Fragmentation means that multiple systems contain the same information, and that common information must be entered separately into each system. For example, facility identifying information (name, address, etc.) must be maintained by each program that has any relationship to the facility; for programs that rely upon multiple databases, the program itself must enter that information into multiple systems. This results in:

Fragmentation exists to some degree within individual programs and, to a greater extent, among different programs.

Intra-program system fragmentation. Some programs lack primary data systems designed to meet the program's information needs. These programs must rely upon several different data systems that typically are not well integrated. The Municipal Solid Waste program, for example, maintains information on MSW permitted facilities in three different systems focused on different aspects of the program's interactions with permittees (original permit processing information, permit modification information, and fee/reporting information). Facility identifying information must be entered into each system. Because there are numerous systems, each with a different "angle" on the facility, a "big picture"view of the facility cannot be created.

Various programs are currently proposing or launching efforts to try to address these fragmentation problems. The Office of Waste Management and the Office of Water Resources Management individually and jointly are initiating projects to integrate and replace currently disconnected systems, to eliminate redundancy, improve efficiency, and enhance data quality and data access for the information users.

Inter-program system fragmentation. Although less debilitating to a given program than intra-program fragmentation, inter-program fragmentation is highly debilitating from an agency perspective, precluding agency staff from easily answering questions such as "Does this facility have a permit from another program?" or "What has its compliance history (across programs) been over the past five years?" Staff believed it would be useful to have access to data from other program systems in order to:

In addition, fragmentation prevents the agency from being able to bring its various sources of information together to develop a cross-media perspective of pollutant releases, interactions with regulated entities, or ambient environmental conditions in order to support the agency's key drivers.

TNRCC has recognized that inter-program system fragmentation is a problem. The agency has investigated the needs for a single facility identifier as a basis for improving information sharing and connections among programs and reducing system fragmentation. The ISP reflects a further attempt by TNRCC to examine needs for integration across the agency.

Poor Functionality of Many Systems

Major databases developed to be omnibus solutions to program information needs (such as TRACS and PSDB) generally have been characterized by staff as difficult to use because of problems with access and functionality (user interface, reporting capability). Smaller databases often have functionality limitations due to the limited experience of the database designer.

Access. In some cases, regional offices may not be able to electronically access the data system, or may have only a few computers that can. The agency budgeting system, for example, is maintained centrally and cannot be accessed directly by program managers; print-outs are received periodically, but program managers need real time access to data to make procurement and budgeting decisions. As a result, most programs/locations maintain "shadow" budget/resource systems that contain the same information that is maintained in the central system.

Functionality. Participants most frequently complained that it was difficult to retrieve information from some systems using canned reports, performing ad hoc queries on the systems, or navigating systems through user interfaces. These were often cited as critical limitations, since one of the primary purposes of an automated data management system is to enable users to sort through a large amount of information readily and to be able to retrieve desired data in a short period of time.

Accessibility or functionality limitations may force staff simply to forego using system data.

Poor Data Quality

A fundamental axiom of information management practitioners is that data quality is directly correlated to data use. Only if the intended users of a system--those most familiar with the data--use the data routinely will data quality problems be identified and corrected (and procedures established to prevent their recurrence). Low system use therefore virtually guarantees that the data in a system is of relatively low quality. Low data quality then adds to "inertia," creating a strong disincentive for staff to learn how to use or to begin using a system ("What's the point? The data is all terrible anyway.") The dynamic reinforces itself.

Perpetuation of the Information Management Problems

Although not all systems suffer from all of these technical limitations, such problems tend to compound one another in ways that further fragment the overall information management infrastructure. As Figure 1 depicts, system problems tend to be self-reinforcing. [Please refer to the figure while reading the following description.] System fragmentation alone (a) limits the agency's ability to leverage its information management investments; but it also leads to the redundant entry, processing, and storage of a great deal of data (b), which typically results in poor data quality (c). Poor data quality is a primary reason staff cite for not using data from TNRCC information management systems (d). Without oversight through use, data quality tends to deteriorate, since common errors cannot be spotted and prevented in the future (c). Poor access to the information management systems which do exist (e) and the poor reporting capabilities of some systems (f) also lead to low system use, creating additional barriers to improving data quality. Staff that cannot or will not use existing systems are likely to develop their own information management capacities to meet their needs (g), further compounding the agency's fragmentation problem.

TNRCC must appreciate the complexity of this dynamic in order to improve the situation. Eliminating current shadow systems as a solution might momentarily reduce fragmentation, but unless the "official" agency system is accessible and functional, staff again will be forced to create new shadow systems that can deliver to them the information they need to function effectively in their jobs.

TNRCC might identify a series of additional investments in information technology to address the technical problems identified here. Technical investments alone, however, will be inadequate. The next section illustrates how organizational dynamics must be addressed, as well, to ensure that systems are designed and maintained adequately to support the agency's information needs on an ongoing basis.

Organizational Dynamics

This section describes the organizational dynamics within TNRCC that compound current information management problems and that must be addressed if TNRCC is to meet its information needs in the future.

Reactive Resource Deployment Due to External Drivers

TNRCC cannot always dictate how agency IT resources will be invested. The agency often must develop new information management systems to respond to information demands created by external forces, including:

Until now, the agency has not articulated a long-term, overarching vision for information management capabilities. Such a strategy, now being articulated through this ISP report, would have helped TNRCC previously to assess emerging information needs against the agency's overall strategic direction and could have helped TNRCC balance necessary reactions with more proactive and deliberate investments. In the absence of such a strategy, and due to the highly unpredictable nature of the external information drivers mentioned above, TNRCC's information management development practices to date have been highly reactive by nature. Because so much of TNRCC's overall investment is spent in a reactive mode, the finite IT resources are stretched thin for addressing more strategic needs, and IRD's ability to improve or even maintain existing systems is highly strained. IRD is only able to respond to a portion of longstanding or newly identified information management problems.

Investment Prioritization and Management

In the absence of an overarching strategy and in recognition of the competition for finite information investment dollars and time, the TNRCC IT Steering Committee's primary function has been to prioritize the numerous information management investments competing for limited IR resources. However, these prioritization efforts to date have not been sufficient to stabilize the agency's overall information management infrastructure.

Information Resources Limitations

TNRCC's IRD, like similar bodies in other state agencies, operates with severe constraints on staff information management expertise and available technical resources. Two key constraints are high staff turnover and limited funding.

Incomplete System Development/Implementation

The "nuclear" approach to addressing program information needs often involves programs in long term, large scale efforts prone to "scope creep" and unexpected costs. Staff tend to conclude that such efforts end up trying to "do too much" and require inordinate amounts of resources (staff time, money). Further, when the scope and time commitment grows, those IT staff and resources dedicated to that project are not free to address other needs, whether planned or emerging. This creates a bottleneck for meeting other needs. It also tends to create increasing pressures to complete the project and deliver something. At that point, the delivered system frequently does not meet the expectations that have been created from all of the time and investment. Further, because of the time and cost overruns to date, and because of competing needs, few or no funds remain to then refine system functionality (reporting tools, user interfaces, etc.) on the basis of initial implementation to maximize the likelihood that the system in fact provides users value.

Limited Regional Involvement

Participants in some user sessions believed that system development efforts in the past had not adequately characterized and addressed regional program needs. Regional staff therefore were often likely to view a new system as a burden (requiring more data collection and entry) without providing corresponding benefits through improved information support. Without perceived benefit, regional staff had limited incentive to sustain a burdensome system, which undermined the system's overall success for all users.

Unmet IT Needs

Although the agency can make targeted improvements in its IT capabilities, some information management needs must go unmet. Programs or staff proposing projects that the IT Steering Committee does not fund, due to overall funding constraints, are often left disappointed and cynical about the agency's ability to improve the information management infrastructure overall.

Staff Dissatisfaction and Pain

The staff dissatisfaction and pain resulting from the limited functionality of existing systems, disappointing systems development efforts, and continued unmet needs drives programs and staff to develop even more information management systems: if no one else will meet their needs, staff will fend for themselves. Non-IR staff can turn to off-the-shelf spreadsheet and database tools to develop simple or even moderately complex systems highly tailored to their specific needs. This leads to even more shadow and regional/personal systems.

Development of Shadow Systems

The proliferation of shadow systems (systems that mirror data contained in other agency systems) and regional/personal databases (highly individual systems that house unique information not in other agency systems) is a less-than-ideal solution, since:

Data/System "Ownership"

In some instances, staff may feel a certain ownership for a system or for the data it contains, typically motivated out of a concern for maintaining the quality of the data and the integrity of its ultimate use. This can both reflect and reinforce the pattern of shadow system development. As long as staff feel that certain data or systems are "theirs," the improved sharing of common official systems will be undermined.

Organizational Reinforcement of Information Management Problems

The organizational context that must be considered when developing and implementing an information strategy is highlighted in Figure 2. [Please refer to the figure while reading the following description.] External influences constantly create the need for new information management systems and are significant sources of system fragmentation. Other factors also contribute to this condition, however. TNRCC's IT Steering Committee prioritizes discretionary system investments in information technology (a) which necessitates that some other potential investments be either deferred or rejected (g), which leaves certain information management needs unmet (h). Projects that are selected must be implemented within the constraints affecting IRD (b), constraints that can result in systems that are not "polished" sufficiently to truly meet users' needs (c). Regional staff have also at times felt that systems were designed without adequate input from them, resulting in systems that did not fully address their functionality needs (d).

Information management needs that are not met (whether due to projects not being funded or due to selected projects not being adequately implemented) leave staff feeling dissatisfied with agency information management capabilities (h) and still suffering from lack of information management support. This in turn drives staff to develop "shadow" systems (I) that contain some, all, or none of the data maintained in other "official" systems designed by the agency, further compounding the agency's fragmentation problem (j).

As TNRCC has recognized, continued ad-hoc investments in improving information technology are not likely to significantly improve the overall information management infrastructure. In many ways, TNRCC faces more of an organizational rather than technical challenge. Investments must be made strategically to ensure that critical links in the chains of organizational dynamics and technical problems are weakened.