Building a digital lawyer?
Stanford/EPA research project experiments with computerizing legal interpretation
By Gale Holland
Digital Government Research Center

The Regnet Project

• Home page • Demo: Regulation Assistance System

Environmental regulations are not for the faint of heart.

Large corporations have whole departments dedicated to hacking through the tangled thicket of state and federal rules and definitions to determine what they must do to obey the law.

Small companies, even individuals, are no less bound by environmental rules. Yet they have neither the time nor the expertise to wrestle with slippery regs and provisions.

This is the problem Kincho H. Law, professor of civil and environmental engineering at Stanford University, tackled when he launched his $1-million Digital Government project, Regnet.

"Regulations are definitely extremely complex, and a barrier for small business," says Law, the project's principal investigator. "A lot of regulations are now on line, but they only allow people to view them. There's no way to find the appropriate regulation for a particular problem."

The demonstration project is geared toward managing or disposing of used oil, a dilemma faced by everyone from the huge computer manufacturer to the mom-and-pop auto repair shop down the street. Work stoppages and fines for breaking a rule can be crippling, especially for the small business owner.

Regnet has taken shape in three phases:

The first was developing a document repository, containing 80MB of text-based content from the federal Environmental Protection Agency (EPA) and the Westlaw legal information database.

The key here was to include not only the EPA codes, but also administrative decisions, federal cases and letters of interpretation from the EPA's general counsel. These supporting documents can radically alter the understanding of what a regulation means.

The next step was making the information retrievable via a searchable concept hierarchy. To date, the text has been indexed alphabetically by EPA hazardous substance, and by U.S. state.

"You navigate a classification hierarchy, like a Yahoo home page," says Stanford researcher Charles Heenan, who is also working on the project. "Where it is very different from Yahoo is [that] the underlying logic will differ."

Four categories of topic-based XML metatags have been affixed to the data:

• Concept tags generate links dynamically to supporting documents, which otherwise do not reference one other. As new supporting documents are added, old text is automatically linked based on the critical concepts they share.
• Reference tags link provisions in one rule to subsections they depend upon in another. For example, a business may be asked to comply with section 40, as stipulated in subsection 29, parts A through F. The key here is that the reference tags specify what they are linking to, rather than where. Thus the system is not bound to a particular source, but can look anywhere for the appropriate reference.
• Definition tags translate specialized words and acronyms into plain English. The huge volume of jargon in federal rules often makes them incomprehensible to the novice. "You're searching 'used oil management,' but you don't know the lingo yet, you might think a burner is for cooking, instead of an oil burner," Heenan explained.
• Logic metadata tags are what makes the third major Regnet component - the interactive compliance assistance tool - possible.

Using a Web interface, the user selects a provision. At each step, the system - using the Otter automated-deduction program (public freeware from the Argonne National Laboratory) - asks the user for input to clarify whether or not he is in compliance. The system automatically inserts hyperlinks to referenced provisions, which can be opened in a new window.

It also displays key technical terms in green text; the text can be "moused over" to display other popup windows with definitions. Key conceptual phrases can be displayed and linked to related documents. The business owner can choose to read a regulation at the provision, section or subsection level.

How it all works is best shown by example:

A business owner logs on to the system and searches for used oil management. A question pops up: Is the used oil stored in a surface impoundment or a waste pile? The business owner answers yes, no or I don't know.

The system then selects an answer - for example, a rule provision specifying when used oil surface impoundments are prohibited, say, as a dust suppressant. A popup window displays the EPA's definition of used oil. The business owner also is prodded to pursue related searches on terms such as waste pile, surface impoundment, dust suppressant etc.

The final result: the business owner is found in or out of compliance.

What Regnet does not do is take the place of a lawyer, Law says. "We're not really interpreting the entire regulation," he says. "We are developing a framework."

"Legal reasoning is much more complex than the reasoning we're doing," says Regnet researcher Shawn Kerrigan. "We're helping to identify issues, as opposed to interpreting the law."

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"The key thing is we're trying to find a methodology to help users access a specific set of regulations as easily as possible, also external and legal documents that might be hidden somewhere," Law says. "So far people seem to think very highly of what we're doing."

The Small Business Administration has shown interest, and Law has been asked to participate in the EPA's compliance assistance forum in San Antonio, Tex., in December, he says.

Other Stanford investigators who worked on the project include Gio Wiederhold, professor emeritus of computer science, medicine and electrical engineering; Barton H. Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law and Vice Dean, school of law, and James O. Leckie, profesor of civil and environmental engineering.