Soon after the terrorist attacks of Sept. 11, EPA began combing its web site for any information that could potentially be used to stage another attack, according to internal agency documents and emails obtained by OMB Watch through a Freedom of Information Act request -- and almost immediately, information began coming down on a scale much larger than previously reported, as this inventory shows. Internal emails give little sense of any criteria used in making these decisions; instead, the objective apparently was to identify any information that might be of use to a terrorist and extract it for re-examination, without giving much thought to the benefits of dissemination. Capturing the prevailing mood at the time, Bob Messina, chief of information systems for EPA Region II, which includes New York, wrote in an email on Sept. 27, “If there are any sites that look like they would offer site specific information about our facilities, especially hazardous chemicals, water supplies, etc, we should break the links.” To push along this search, EPA headquarters delivered an agency-wide request in late September -- covering all of its program areas and 10 regional offices -- asking those in the agency responsible for disseminating information to identify potentially “sensitive” information, particularly “resources which provide information on chemicals, and/or location, and/or amounts, and/or impacts on the environment or human health,” according to an email from Emma McNamara, director of EPA’s Information Access Division of the Office of Information. McNamara provided a template to identify such information, requesting a recommendation “as to its level of vulnerability: take it down or leave it available for public access” (although none of the records provided by EPA indicate that this template was actually used). Unfortunately, as EPA took down information, it failed to keep a centralized log of what information had been removed. In an email on Sept. 28, Richard Stapleton, head of EPA’s Region II communications division, wrote to colleagues, “A quick review of the material being deleted leaves the impression that the list is excessive. Let’s keep track of everything taken down so it may be reviewed once we have better established criteria that balances the need to protect sensitive information while continuing to conduct our work in a public manner.” Yet this never happened. Indeed, in honoring OMB Watch’s FOIA request, EPA’s FOIA officer had to ask each region and program office what information they had removed, indicating an inventory had not been compiled previously. Even after this information was gathered, EPA did not provide OMB Watch a list of the removed information in the form of an inventory; instead, EPA merely provided copies of removed documents, as well as emails that referred to removals, which OMB Watch itself converted to an inventory. This lack of oversight may explain the incoherence demonstrated in EPA Region VII’s decision to remove information on the locations of water intake systems, as well as regulated facilities and pipelines, while other regional offices continue to post this exact type of information. Moreover, it helps account for testimony by Elaine Stanley, director of EPA’s Office of Information, before the House Transportation and Infrastructure Committee on Nov. 8, in which she stated, “Of all the information resources screened to date, only Risk Management Plan Information (RMP Info) has been removed from EPA’s web site...” Yet clearly, as the inventory compiled by OMB Watch demonstrates, this was not even close to accurate. EPA headquarters seems to have been unaware what was going on in program and regional offices. Nonetheless, during October, EPA did complete a comprehensive inventory of all its publicly available information (which by law, should have been previously prepared, as OMB Watch has long pointed out). From this inventory, EPA began a more systematic evaluation -- including of information that had already been removed to see if it should be reposted -- using newly established criteria, which unfortunately, still remain murky. EPA did not provide OMB Watch with any formal criteria. Instead, all we have is a brief summary of the criteria from Stanley’s testimony: “EPA has developed four criteria for assessing the sensitivity of our information resources: ‘type,’ ‘specificity,’ ‘connectivity,’ and the ‘availability’ of information. Information on a facility’s or a pollutant’s location, chemical identification, volume, acute effects, and plant processes and management falls within the ‘type’ criterion. The ‘specificity’ criterion builds on the type of information and assesses the level of detail available for each type. The ‘connectivity’ criterion looks at the degree to which individual pieces of information can be connected to create realistic scenarios. Finally, the ‘availability’ criterion assesses the level of control that EPA has over releasing the information. This criterion ascertains whether or not EPA is the sole provider of a particular piece of information. If information is widely available through other sources outside of EPA’s control -- such as information available from State or local government agencies, public interest groups, in textbooks or from universities -- then EPA’s removal may not substantially alter its availability.” Given this last criteria, it would be particularly interesting to hear EPA's justification for its continued withholding of RMP information. OMB Watch provides public access to the executive summaries of RMP data through our Right-to-Know Network, which was obtained from EPA prior to Sept. 11. It remains widely available, yet EPA has not restored public access to the same information through its web site -- and unfortunately, no explanation has been given. Moreover, Stanley's description does not address the critical issue of how EPA ultimately balances the benefits of public access to information, which are many, against possible security concerns. In other words, after describing information on the basis of these four criteria, what happens next? EPA withheld a large volume of documents from OMB Watch, listing only document titles, citing the “deliberative process” as the basis for withholding. A number of these documents likely would provide an answer to the above question. For example, a document from January, is titled, “Draft manuscript ‘EPA Information Access: Developing a Criteria for the Sensitivity of Data.’” What makes the withholding of this document and others like it especially frustrating is that EPA is clearly employing criteria. Stanley testified, “At this time [Nov. 8], over 180 resources have been assessed using this criteria.” The document titles also indicate a number of ongoing reviews, including of RMP information, as well as information from EPA’s Office of Research and Development. The public and the users of EPA information have been completely shut out of this process, and we can only wonder how the criteria are being applied. Even after the fact, when a decision has been made to remove information, EPA has provided almost no explanation. OMB Watch’s FOIA request asked for “any justification for any decision to remove or limit information.” Yet we received nothing; instead, EPA’s approach remains a mystery.