UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                              WSG 169
                                                         Date Signed: September 10, 2003

MEMORANDUM

From:        William R. Diamond, Director
             Drinking Water Protection Division

To:          Regional Drinking Water/Source Water Branch Chiefs,
             Region 1-10

Subject:      Interim Data Security Procedures for Handling State SWA Polygon Data
       At the request of GWPC and several states, I want to reaffirm the security procedures we
currently have in place for handling source water area (SWA) polygon data we receive from the
states.  OGWDW holds the State polygon data in a protected development servers and restricts
access to only those involved in developing the SWA data repository. By agreement with each
state, no one else will have access to the data until the state reviews EPA's security policy and
authorizes EPA to release its data for production use.  These interim data security procedures
will remain in effect until we establish a data security policy on handling the SWA polygon and
related source water assessment and protection data reported to EPA by the states. Once EPA's
data security policy is in place, our agreement is to offer the states the option of having their data
deleted from EPA's data base if the state determines that EPA's public access policy is less
restrictive than the comparable State policy.

       As you know, I announced the start of our quest to develop our own GIS  coverage of the
State delineated source water areas in late September, 2002. From the start, we committed to
securing the state data from access by anyone other than those working on developing EPA's
database until we published our long term data handling policy. This commitment is
documented in the "Frequently Asked Questions (FAQ)" paper we developed to  address the
policy and procedural issues raised by the states about the initiative. We have been remarkably
successful in working with the states in developing our SWA polygon coverage.  Currently, we
have SWA polygon data from 19 states and agreement with nine others and D.C. to submit their
data. Our SWA polygon coverage is the foundation for the pilot effort with GWPC and
ASDWA to begin implementation of the measures guidance this year.  The success we have had
with the states depends to a large extent on our commitment to protecting the state data until the
security policy is settled.

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                                                                               WSG 169

       We are working with the key groups in EPA and the states to publish a data security
policy related to the SWA polygons and related source water assessment and protection data. I
am hopeful that we'll have a policy in place over the next few months that will meet the
concerns of most of the states. Until then, we plan to continue working with as many states as
we can to resolve the technical challenges of building a consistent GIS coverage of the State
delineated source water areas. Your active involvement in working with your states on this
initiative is appreciated.
Attachments

cc:     Chuck Job
       Roy Simon
       Jim Taft, ASDWA
       Michael Paque, GWPC
       Regional Source Water Representatives

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