Challenges and Opportunities Facing Platypus LLC. Non­Market Strategy Analysis Project Report

Department of Engineering and Public Policy New Technology Commercialization: Non­Market Public Policy Strategies for Entrepreneurs and Innovators

Carnegie Mellon University

Pittsburgh, PA

Clients Paul Scerri, John Scerri, and Abhinav Valada

Platypus LLC.

Project Team Alexander Fry and Chayoot Chatunawarat

Faculty Advisors

Dr. Deborah D. Stine and Dr. Enes Hosgor

MAY 2014

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Disclaimer and Explanatory Note Please do not cite or quote this report, or any portion thereof, as an official Carnegie Mellon University report or document. As a student project, it has not been subjected to the required level of critical review. This report presents the results of a one­semester university project that is part of a class offered by the Department of Engineering and Public Policy at Carnegie Mellon University. In completing this project, students contributed skills from their individual disciplines and gained experience in solving problems that require interdisciplinary cooperation. Acknowledgements: We wish to express our thanks to the following individuals for their advice during the project: Paul Scerri, John Scerri, Abhinav Valada, John Paul Jones, Austin Mitchell, Yao Zhu & Jason T. Jasko (University of Pittsburgh Environmental Law Clinic), Deborah D. Stine and Enes Hosgor

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Table of Contents

1. Executive Summary……………………………………………………………………………...4 2. Technology Overview…………………………………………………………………………....5

2.1 Company Overview………………………………………………………………….. ..5 2.2 Technology Platform…………………………………………………………………..5 2.3 Market Opportunities…………………………………………………………………..6

3. Challenge & Opportunity Identification………………………………………………………....9 4. Policy Context……………………………………………………………….…………………11

4.1 EPA Certification………………………………………………….………………….11 4.2 Incentive to Test…………………………………………………….………………...12 4.3 Financial Opportunity………………………………………………………………...12

5. Policy Forum…………………………………………………………………….…………….. 14 6. Range of Outcomes……………………………………………………………………………. 16

6.1 EPA Certification……………………………………………………………………..16 6.2 Incentive to Test………………………………………………………………………17 6.3 Financial Opportunity………………………………………………...………………18

7. Bargaining Context……………………………………………………………………………..21 7.1 EPA Certification……………………………………………………………………..21 7.2 Incentive to Test………………………………………………………………………22 7.3 Financial Opportunity………………………………………………...………………23

8. Strategy…………………………………………………………………………………………25 8.1 Gaining EPA certification……………………………………………..……………...25 8.2 Offering incentive to use Platypus’s water quality monitoring …….………………..26 8.3 Gaining USAID funding……………………………………………………………...27

References………………………………………………………………………………………... 28

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1. Executive Summary

Platypus LLC, an independent company formed out of a research group at Carnegie Mellon University, has developed an autonomous robotic boat platform for monitoring various characteristics of water quality and culture. The company markets the product, nationally and internationally, for use in flood mitigation and water culture testing, in both private and public environments. One of the promising potential markets is Environmental Protection Agency (EPA) compliance monitoring, where pollutant dischargers are required to monitor water quality in their discharging areas. In this market, the main challenges in the non­market environment are gaining EPA certification and incentives for autonomous testing by a robotic boat. Although Platypus’s robotic boat offers a fast and cost­effective alternative to monitor water quality, EPA does not currently have applicable guidelines to certify Platypus’s testing methodology. While other robotic monitoring developers would have aligned interests with Platypus, non­robotic monitoring service providers and water polluters who need to comply with EPA regulations would oppose the exploitation of a water monitoring robotic boat. EPA, which has a mission to protect the environment, could offer the certification and incentives for a water monitoring robot, but it also has to balance benefits to the public with burdens on water polluting corporations. Another facet of the report will explore potential opportunities for Platypus. Due to its diverse applications, Platypus has many financial opportunities that would be important for Platypus to sustain its business in long run. The report will analyse alternate options, regarding these challenges and opportunities, according to four main criteria: effectiveness, efficiency, responsiveness, and equity. Effectiveness is the extent that the proposed strategy, if successful, fulfills the desired outcome. Efficiency refers to the cost of implementing a particular strategy, in terms of both monetary and non­monetary inputs. Responsiveness refers to the likelihood that policy actors will adopt the strategies. Equity refers to the impact of the proposed strategy towards concerned parties­ including the public, customers and competitors. After comparing and contrasting alternatives, it is recommended that Platypus follow the EPA’s requirements for automatic samplers, as much as possible, and validate their testing data with those taken using current practices, so as to solicit certification from EPA. In addition, Platypus ought to exploit the EPA’s Audit Policy to incentivize its customers to use its service, since this program offers significant penalty reductions to those who work aggressively­ beyond basic regulation requirements­ to ensure high water quality. Finally, Platypus should seek funding or grants from the U.S. Agency for International Development (USAID), which regularly supports projects in Platypus’s research area.

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2. Technology Overview

2.1 Company overview Established in 2012, Platypus LLC is an independent company in Pittsburgh. It is a spin­off from Carnegie Mellon University’s Robotics Institute, with financial and mentoring support from Innovation Works, the Center for Technology Transition and Enterprise Creation and Project Olympus. It is working with several public and private organizations to provide water monitoring solutions, using autonomous robotic boats. Platypus has a versatile range of boats, which can monitor a variety of water bodies, from small streams and fish farms to large lakes and bays. They perform work both nationally and internationally. 2.2 Technology Platform Platypus technology platform is a system of robotic boats integrated together with smartphones and sensors to operate in an aquatic area. The Platypus boat (as shown in Figure 1) is a floating machine that has a fan on the top. The dimensions of the boat are approximately 4 feet (length) by 2 feet (width) by 8 inches (height). This fan generates propulsion to drive the boat. The fan can be turned by the motor in the direction which a controller orders. The boat is designed to be stable in water with waves and disturbances, as well as in shallow water. Moreover, it is scalable; i.e., larger, or smaller, versions of the boat can be used for varying circumstances. In large area, many robotic boats can also be used to collect data together, decreasing monitoring time.

Figure 1: Platypus Boat [image from Platypus 2014]

The Platypus technology platform is designed to be compatible with a smartphone that operates on an Android system. Before being connected to the robotic boat, a smartphone will be installed with software that is programmed to perform monitoring work. It also serves as the communication system, as it can send data to other devices or the database via cellular or wifi connection. The Inertial Measurement Unit (IMU), which is embedded in the phone, can sense the velocity and orientation­ this data is vital to navigate the robotic boat. Another important component is the global positioning system (GPS). This component can figure out where the boat is located while it monitors environmental data. To monitor specific data, the robotic boat will be attached with sensors. The normally used sensors include

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electrical conductivity (EC), pH, temperature, depth, dissolved oxygen and (DO) sensors. Other sensors can be mounted according to the customer’s needs. These sensors will collect data from distributed points in the area. Then, this data will be processed and depicted as a graphical chart (as shown in Figure 2). In this way, the conditions of water will be fully understood, while the current methods collect data from a few points, which may not be representatives of the whole area. Also, the robotic boat can be equipped with a tool to collect a water sample, in case that laboratory tests are needed.

Figure 2: Graphical data [image from Platypus 2014]

Furthermore, for security application, a camera may be used to record or send a real­time video to the users. To extend the distance and time the boat can travel, a floating charging station can be used. The charging station has a solar cell panel to collect the solar energy and store that energy in its battery. When the robotic boat runs out of energy, it will head to the station and charge its battery. 2.3 Market Opportunities Platypus is currently working with customers in a variety sectors. One of its customer groups is environmental groups. Platypus can help them locate pollution origin (where the chemical is released), without using volunteer manpower to monitor. Platypus also works with lake management companies and the Port of Pittsburgh, to help them collect data in distributed spots in a body of water. Moreover, it can collect data so that researchers can conduct studies on an environment. While sampling dangerous areas­ e.g. the habitats of alligators or hippopotamuses­ researchers can reduce risk of bodily injury by sending Platypus boats in place of human testers. Additionally, its platform is potentially useful as media in education, because it is relatively inexpensive and has a variety of functions. Students can study robotic technology from it, or use it as a tool to study water ecology. The future plan of Platypus is to expand its business to other customer groups, such as flood relief, aquaculture and EPA compliance testing. With regards to the flood mitigation market, Platypus has demonstrated the efficacy of its product, during a trial in the Philippines, in September 2011 [Platypus website, Flood Mitigation, senseplatypus.com]. Platypus used 5 robotic boats to monitor water in 7 different locations. In the aquaculture market, Platypus plans to open Platypus­China, with Nanjing

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University, to work with the shrimp and sea cucumber farm market [CRW website, blogspot.com]. The robotic boats can monitor dissolved oxygen (DO) content and water temperature, so that the farm owners have up to date information on their ponds. With this information they can make a more informed decision as to what needs to be rectified, in cases of fish deaths. In the EPA compliance monitoring market, there are two types of water monitoring: point source monitoring and nonpoint source monitoring. For point source monitoring, the locations of pollution source are known, so the monitorings are needed to conduct only at points of water discharge. For nonpoint source monitoring, the locations of pollution cannot be defined accurately. For example, the pesticides used in agriculture seep through the underground to the water resource. In this case, large area of water should be monitored. There are a few potential customers in this compliance market. The Environmental Protection Agency (EPA) regulates industries that discharge pollutants into water and requires them to monitor water periodically. There is an opportunity to provide services directly to the EPA, especially with regards to the baseline water quality testing that EPA performs. Another possible customer is the group companies or other polluters that empty into waterways. Platypus can collect and submit the testing data that is needed to comply with EPA Clean Water Act monitoring regulations. Also, within the corporate market, Platypus could sell its services to drilling companies, such as those that perform hydraulic fracturing, in order to demonstrate to the public a visible display of voluntary environmental testing. This could help to assuage public anger and fear over these companies’ supposed cavalier attitude towards environmental protection and testing.

Intellectual Property Per conversation with the Platypus team, Platypus does not hold any patents on its technology and is not licensing any patented technology. Open Source Software Platypus uses open source software in the operation of its robotic boats and data processing. This software is available for download at www.github.com. Approval for Use Platypus has identified EPA certification, for their system, as a key necessity for commercialization. Platypus uses EPA certified sensors, but they also need certification for their autonomous boats and their sampling and testing plan, if they are going to be used for EPA water quality compliance monitoring. The Platypus team has made contact with people at the EPA, among them a program manager in the EPA’s Green Chemistry Program. According to the Platypus team, response has been generally positive from the contacts at the EPA. Supporting regulations to require more robust testing standards and gaining EPA certification for their testing methods are both clear goals for Platypus LLC. Government Incentives Even though EPA appears satisfied with this technology, at the current state, Platypus does not receive many incentives from government. In the future, Platypus may decide to seek fund or grant from the governmental organizations.

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Standards Because monitoring robot technology is quite new, there are no currently published standards for Platypus to follow. Platypus could work with EPA to develop these standards, so as to eventually obtain certification from EPA, gain acceptance from its customers and ensure that a high quality product enters the market. Strategies for achieving this goal will be discussed in the following sections of this report. Data Security and Privacy There is a clear need for Platypus to protect the testing data. Both the corporations involved and environmental advocacy groups have an interest in the data. In order to ensure that the data is not tampered with and not stolen, Platypus needs to encrypt their data transmissions and ensure proper security standards. There is also a security concern, regarding the possible commandeering of autonomous boats by nefarious agents. Platypus must deal with this issue, if they have not already.

Environment and Health The autonomous boats are battery powered. Platypus plans to charge the boats using solar powered charging stations, located near the launch sites. The main environmental concerns would thus come in the manufacturing process. Health concerns include the possibility of rogue autonomous boats running into humans, animals or other boats.

Spectrum The boats communicate with the operator through use of a cell phone, running Android OS; they thus make use of wireless (EDGE, 3G, or wifi) technology. Thus, their spectrum usage mirrors that of cell phones. As long as the boats do not use other spectrums, or run into obstacles of unavailable networks (e.g. due to natural disaster), the spectrum issue will not be a main concern. Ethics and Human Rights One possible ethics violation, on the part of corporate consumers, could be the hiding of data that is harmful to business. Platypus could manage this potential problem by encrypting their data and sending their recorded data directly to the EPA. Thus, they would remove the possibility of tampering, on either Platypus’ or the company’s ends, by removing human interaction from the reporting cycle

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3. Challenge & Opportunity Identification

Platypus faces a number of challenges in the nonmarket environment, including: lack of certification for their autonomous testing platform and lack of incentive for using Platypus products­ due to current testing regulations. Where challenges exist, however, there are often opportunities to improve one’s standing, through nonmarket action. Some of these opportunities include: gaining funding from EPA for water monitoring, and gaining USAID funding for disaster mitigation One nonmarket factor that is affecting the commercialization of Platypus’ technology, is the ability to gain EPA certification for their testing platform. The boats use EPA certified sensors, but their robotic apparati are not certified to perform water testing. Through conversations with Platypus and information in Platypus’ business overview presentation, it is clear that the EPA does not have a clear plan for certifying the boats. Platypus notes that the EPA has been receptive to the autonomous boats idea, but that they do not know how to certify them [Platypus presentation]. Current water pollutant compliance testing is performed in accordance with the National Pollutant Discharge Elimination System (NPDES). According to this system, recommendations and specifications are set forth for certified testing methodologies. Under the current system, the Platypus autonomous boats, under the current operation, would not qualify the requirements to get the certification. Thus, a key objective of Platypus’ strategy should include gaining certification for their testing platform. Another challenge for Platypus is the lack of incentive for companies to use Platypus’ technology. Under current EPA regulations, the frequency and quantity of testing required by the EPA is low. Some companies are only required to test at points of entrance to waterways, as per the Clean Water Act (CWA), while Platypus’s service generally performs the testing in a large area. As a result, the necessity of testing performed by Platypus is questionable for companies that are simply attempting to comply with regulations, since the current standards require only sporadic, low quantity point­source testing at discharge points. Furthermore, companies are worried both about price of monitoring a larger area than needed and the liability of possibly finding non­compliant results when testing was not required. This has led Platypus to look for customers in environmental groups and private fish farms. Either a regulation to require more testing or an incentive to test and self report could encourage companies to hire Platypus’ services. One non­market opportunity for Platypus comes in the form of environmental protection agencies as customers. This organization could be either the EPA, at the national level, or the Pennsylvania Department of Environmental Protection (PA­DEP), at the state level. In the domestic market, Platypus could seek out the EPA/PA­DEP to sell their product for environmental compliance testing purposes. The current practice of water monitoring is point source monitoring at the point of entrance into a waterway. This method does not provide a broad picture of water condition in the whole area. With Platypus’s relatively low­cost technology, water condition can be monitored thoroughly without adding a large burden to the industry, leading to more effective pollution control. Ultimately, EPA/PA­DEP has a role to protect environment for the public. Lingering sentiment from the public and environmentalists for better water testing could lead to a partnership with the EPA/PA­DEP for Platypus.

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Another non­market opportunity for Platypus comes in the form of USAID (U.S. Agency for International Development) as a customer. Platypus has already demonstrated the efficacy of their product in flood mitigation operations. In fiscal year 2013, USAID provided $68.8 million in flood relief to countries around the world [USAID Budget Report FY2015]. Although much of this money was likely used for hunger relief, electricity and shelter, the discretionary nature of the relief spending opens up the market to Platypus. In these disaster situations, Platypus could test for pathogens, monitor water height and use cameras to look for stranded individuals. The ability to operate the boats from a safe distance would be an appealing prospect for foreign and domestic workers, in dangerous flood situations. USAID has shown a strong initiative towards technology spending in recent years. They recently announced the decision to open a one hundred million dollar research facility, in the United States [Gewin 2014]. One of the stated areas of research is in “sustainable water solutions”. Thus, it is clear that USAID is making a commitment to research relevant to Platypus technology. The fact that Platypus has already proved its capability in such situations makes this a serious avenue of consideration for the technology. Other opportunities include work on private fisheries, waterway management companies, and USGS (U.S. Geological Survey). Platypus has already worked in these markets, and as a result could continue to do so. If the pathway to EPA certification proves to be long, these smaller markets may prove to be a necessary bridge in funding.

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4. Policy Context Status Quo One of the prospective markets for Platypus consists of water quality monitoring services. These services include both baseline testing of public waterways and testing of water discharge points, for EPA and NPDES compliance. Compared to other technologies that are used for this type of monitoring, Platypus’s robotic boats offer an inexpensive alternative. To monitor 10 parameters (e.g. pH, temperature, dissolved oxygen concentration) of water condition in one acre, Platypus’s service costs about $490, whereas manual sampling cost up to $3,000­6,000 [Platypus presentation]. However, the current EPA regulations and resulting monitoring program (NPDES), do not have a written guidance document for certifying the autonomous water monitoring procedure performed by Platypus [Platypus presentation]. This is the main nonmarket factor that prevents Platypus from penetrating the EPA compliance market. 4.1 EPA Certification To gain traction in the compliance monitoring market, Platypus needs to obtain EPA certification for its water quality compliance monitoring technology. Otherwise, their ability to compete in this market will be severely limited. It is the most important factor for Platypus to be successful in the environmental compliance market. Some potential alternatives to gain EPA certification for Platypus’s robotic boat are detailed below. 4.1.1 Work with EPA directly to gain certification at the federal level. Platypus may seek a change in compliance monitoring, specifically in the Clean Water Act. Previously, Platypus has contacted EPA; they state that the EPA are in favor of Platypus’ technology [Platypus presentation]. The sensors that Platypus uses to monitor water are certified by the EPA. The primary barrier is that there is no specific certification process or standard for autonomous robotic boats. The use of a consulting firm, which specializes in work with the EPA, could help in this process. An internet search returns numerous results for EPA consulting firms, in the Pittsburgh area. One firm, specializing in EPA monitoring and compliance, is CP Environmental Group (http://www.cpeg­inc.com/). 4.1.2 Partner with company, to send NPDES data to Pennsylvania DEP Platypus can provide testing services to a company, by providing their NPDES compliance data. Sending this data to the PA­DEP forces the issue, by requiring the department to comment on the validity of the testing method. If the data is accepted, Platypus will have gained statewide acceptance for their compliance monitoring. If the data is rejected, Platypus will have written confirmation of what they need to change in their testing scheme. 4.1.3 Work with governor’s office to gain certification at state level. Although the EPA is a federal agency­ responsible for regulations throughout the United States­ they delegate many testing and compliance tasks to individual state environmental departments. In the case of Pennsylvania, this department is the Department of Environmental Protection (DEP). One method for seeking state acceptance of Platypus’ technology involves interacting with the governor’s office to pressure the state DEP into action. While working with the state DEP, Platypus could simultaneously with the governor, to develop new certification procedures for water monitoring robotic boats. 4.1.4 Engage Congress members to petition EPA to develop certification. Platypus can ask local members of Congress to petition EPA to develop a certification process for autonomous robotic monitoring of water quality. In some regions, the public awareness of water quality is significant. Civilians who live near hydraulic fracturing operations or petrochemical plants may be relieved to see more advanced technology used in monitoring of their local water resources. Some local Congressman should be of special consideration for Platypus, because of their public political stances and memberships in relevant committees. Senator Bob Casey Jr. is a member of the Senate Committee on

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Finance and the Committee on Agriculture, Nutrition and Forestry [Bob Casey website, senate.gov]. Congressman Mike Doyle is a founding member of the House Robotics Caucus, whose mission is “to ensure that our nation remains globally competitive in the field of robotics” [Mike Doyle website, house.gov]. As a result of these Congress members’ memberships in relevant Congressional committees, and the residence of Carnegie Mellon within their districts, they appear to be the best candidates for contact within the federal Congress. 4.2 Incentive to test Assuming Platypus succeeds in the first avenue, the next area that Platypus should focus on is encouraging customers to use its services. Platypus is capable of providing large amounts of graphical data on various water parameters, which provides researchers and policy makers with a clearer and more detailed picture of overall water culture quality. Under current EPA procedure, compliance testing requires only small quality testing at point sources. The Platypus team must convince corporate or government customers that the benefits of the product are sufficient to counteract the cost of larger scale testing. The following alternatives address this challenge. 4.2.1 Support laws to require graphical data for water quality compliance monitoring. As the current regulations require only point data for compliance monitoring, there is low incentive for companies to monitor water throughout the larger area surrounding the points of release. This alternative supports the most stringent government intervention, in that it forces all companies and other polluters to monitor for graphical data. 4.2.2 Offer penalty leniency to companies that monitor for graphical data. This alternative would not demand graphical data for compliance monitoring, but instead would incentivize companies to seek graphical data, by providing leniency to those who monitor for graphical data. 4.2.3 Join forces with environmental non­governmental organizations to campaign for graphical data. This alternative involves Platypus joining forces with environmental groups, who would likely support the Platypus goal­ to get a clearer and more detailed picture of water quality through large, graphical data. The campaign would put pressure on both private and public sectors to take action on this issue. 4.3 Financial Opportunity The last strategy Platypus should execute is to find opportunities to fund and diversify its projects. Because the nonmarket strategy to enter compliance monitoring market may take a long time, it could also find other funding and market opportunities. 4.3.1 Seek funding from EPA With EPA certification, Platypus would seek to gain EPA funding for providing monitoring services of base water quality in public water resources. They could also seek to provide the EPA monitoring service for corporate point source testing. Should EPA certification prove unsuccessful, Platypus could seek grants for particular water monitoring jobs. Open grant solicitations can be found at the following web address: http://www.grants.gov/web/grants/search­grants.html. A search for “water monitoring” returns a number of grants, of relevance to Platypus’ technology. 4.3.2 Find Corporate Sponsor Another alternative is to gain financial support from corporate sponsor. Some firms may be interested in developing more cost­effective water quality compliance monitoring. Or they may prefer to raise the monitoring standard over than the requirements by the regulation as parts of their corporate social responsibility (CSR) programs. 4.3.3 Partner with USAID to support its international market. As Platypus’s technology can contribute to the society globally, it has potential to get support from USAID. This U.S. government agency usually supports the projects that aim to address the key global

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issues. There are two major themes fit with Platypus’s project, which are Water and Sanitation, and Environment and Global Climate Change. USAID has a partnership program “Grand Challenges for Development” that Platypus could participate to develop its projects. Alternatively, Platypus may seek funding from “Development Innovations Ventures”, an open competition supporting external projects that aim to address key global challenges. 4.3.4 Collaborate with NGOs to monitor environment. Offering a variety of applications, Platypus’s water monitoring method could attract the support of NGOs such as Environmental Defense Fund (EDF) or National Resources Defense Council (NRDC). Platypus could aid these organizations in their projects to inspect pollution in water resources and survey conditions of aquatic animal habitats. For example, NRDC (Natural Resources Defense Council)­ a national nonprofit environmental organization­ works to protect the world’s natural resources, public health, and environment. Hence, it could be a good candidate of partnership for Platypus. 4.3.5 Continue expanding business in aquaculture sector. Platypus may also market more in aquaculture sector. It can offer services to monitor fish or shrimp farms and alert when the conditions are not suitable for farming. In this market, Platypus does not need any certification. More importantly, its service can monitor the water condition more thoroughly with affordable price. Thus, it is a great opportunity for Platypus.

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5. Policy Forum

The following are important forum locations, for discussing the implementation of this technology: 1. Environmental Protection Agency (EPA)­ for certification and regulations discussions There are a few ways to interact with the EPA. First, the Platypus could communicate directly to a member of the EPA staff. The Platypus team could provide technical leadership on the certification process, or provide contacts in academia/industry that could serve as independent technical experts on the issue. A second method of interaction is to provide comments on the EPA online forum. This forum is set up to receive relevant information on potential regulations. once the process has begun to create a regulation, there is a formal process which must be followed. This includes a technical, rule writing stage, followed by formal and open debate and eventually drafting of a regulation. Furthermore, EPA has some collaborative program to develop robotics to use in the environmental protection. One example is the partnership with the National Institute of Environmental Health Sciences (NIEHS) National Toxicology Program, the National Institute of Health (NIH) Chemical Genomics Center, and the Food and Drug Administration (FDA) in Tox21 project to develop revolutionary toxicity testing methodology [EPA website, The Future of Toxicity, epa.gov]. Hence, it is possible that Platypus could partner with EPA to advance their technology further. 2. Pennsylvania Department of Environmental Protection (PA­DEP)­ for monitoring and testing data approval in PA PA­DEP has a mission to protect environment from pollution for health and safety of Pennsylvania’s citizens. Within PA­DEP, the Bureau of Point and Non­Point Source Management (BPNPSM) is the key forum for Platypus as it oversees Clean Water program of Pennsylvania. It has direct responsibility to implement water quality monitoring and assessments; and National Pollutant Discharge Elimination System (NPDES) programs, which are related to Platypus’s water quality monitoring services. 3. State Governor’s Office­ for implementation of testing on a state­wide level This forum could be used by Platypus as a possible avenue for gaining certification. The process by which laboratories are certified goes through the state Department of Environmental Protection. As a result, the ability to gain certification lies partially at the state level. The office of the governor may be able to pressure the Department of Environmental Protection to consider new certification processes and standards. 4. U.S. Agency for International Development (USAID)­ for partnership or grant funding USAID is a federal agency, which works to provide funding and relief to foreign institutions. There is a formal contract process, through which Platypus could pass to gain funding for international relief work. Platypus has previously demonstrated the ability to work in flood relief situations. Contact with the USAID science and technology leads could lead to entrance into the USAID funding market. Also, Platypus can apply for solicited opportunities or propose unsolicited programs that support the priority areas of USAID, including “Global Climate Change” and “Water and Sanitation” The following organizations are likely to support action on some options: 1. Environmental protection NGOs­ who want more rigorous environmental testing and protection Greenpeace and WWF are examples of NGOs in global avenue that may be in favor of Platypus. River Alert Information Network, Three Rivers Waterkeeper, and Pinchot Institute are local organizations in U.S., interested in monitoring water quality. Also, although some minor environmental concerns exist anytime a man­made structure enters a natural habitat, the footprint of Platypus boats is low. Thus, environmental groups are likely a supporter of Platypus’ monitoring technology­ both for its ability to monitor aquaculture and water quality; and its improvement over the current­ fossil fuel intensive­ testing procedure.

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2. Fishing enthusiasts and outdoorsmen Similar to environmental conservation groups, fishing and hunting enthusiasts are likely to support improved aquaculture. The concern of these groups, however, is likely driven by concern for fish supply. Thus, Platypus could use the ability to test for hypoxia and water toxins­ both harmful to fish health­ as a reason for Platypus’ usefulness. 3. Competitor robotic monitoring developers Robotic Fish project of Michigan State University and Floating Sensor Network project of University of California, Berkeley are developing robotic systems to monitor quality of water. These groups, although their technologies vary, would also likely support robotic certification and more rigorous testing, because their businesses have similar needs to Platypus. 4. National policymakers who favor more rigorous testing Many lawmakers will support the rise of water monitoring standard because they have high awareness in environment or their constituents would like to see more effective control of pollutants in their area. If Platypus started penetrating markets in an industry­intensive region, where environment is a key issue, it would get more support from policymakers in those regions. The following organizations are likely to oppose action on some options: 1. Companies responsible for testing their pollution sources to waterways Companies that discharge to waterways are likely to oppose more rigorous testing standards, because the new standards mean more costly testing and a higher chance of a harmful test. Platypus could attempt to make this group supportive, by supporting “self reporting leniency” or by offering testing services to these companies, as a preemptive safety net before official testing. 2. Current, non­robotic, testing companies The companies with traditional testing methods are unlikely to support certification for autonomous boats, because such an action reduces market share. Especially, those who offer manual sampling services tend to oppose strongly the approval of certification and regulations of autonomous robotic boats. 3. National policymakers who do not want to increase the environmental testing burden on companies or increase the tax burden on citizens to pay for extra testing Certain lawmakers oppose any action that would increase burdens on businesses, government spending or the tax burden on the public. These lawmakers would need to be convinced that the increased testing would improve quality of life for the public, in some tangible way. 4. Opponents of autonomous technology Some people may oppose autonomous robotic boats because of a general fear of new technology. Some may fear that the boats are a security or privacy concern­ e.g. that they could be hijacked. Lastly, some may fear that the boats are less reliable than a human operator.

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6. Range of Outcomes

In this section the effectiveness and efficiency of various strategies will be discussed. Effectiveness refers to the extent to which the proposed strategy, if successful, fulfills the team’s desired outcome. Efficiency refers to the cost of implementing a particular strategy, in terms of time and financial input. For each strategy, the effectiveness and efficiency will be judged on a relative scale, with three grades possible. When used to rank effectiveness, the scores represent the following: Plus (+): Strategy is likely to achieve outcome Minus (­): Strategy is not likely to achieve outcome Even (0): Strategy may, or may not, be likely to achieve outcome

When used to rank efficiency, the scores represent the following: Plus (+): Strategy does not use an abundance of resources (time and financial) Minus (­): Strategy uses an abundance of resources (time and financial) Even (0): Strategy may, or may not, use an abundance of resources (time and financial) 6.1 EPA Certification The desired outcome for Platypus, in this domain, is to gain EPA certification for their testing platform and procedure. In this section both the effectiveness and efficiency of this goal are evaluated, for each of the proposed strategies, and the status quo. The status quo, discussing with a member of the EPA, is quite effective to achieve the desired outcome ­ EPA certification. The members of EPA may bring the issue to change current certification standards, leading to federal level certification approval for autonomous robotic boats. However, this method is inefficient, because it requires Platypus to travel to discuss with EPA policymakers many times, and the total amount of time from discussions with EPA members to new EPA certification for water testing robotic boat could take very long. That means Platypus might lose an advantage, because other companies may successfully develop similar robotic boats to compete with Platypus. The first alternative, working actively with EPA, is likely to be effective in gaining certification, since EPA has direct responsibility for this process. Platypus could do this by proposing to high level EPA officials or filling the online form, at http://www.regulations.gov/#!home. They could support their claims of testing reliability by comparing testing results from the autonomous robotic boat with similar results from current testing methods. The efficiency of this alternative is quite high, since the time required to get the approval would be much less than the status quo. The financial requirement is moderate, since Platypus will need technical and law teams to provide supporting information to the EPA. The second alternative, to partner with a company and submit the data to PA­DEP, is likely of a moderate effectiveness as the certification would be valid only in the state level. This alternative is quite efficient as it is not necessary to hire a lawyer to interact with PA­DEP’s officers. Platypus only needs to perform water quality monitoring for its partner company and submit data to the PA­DEP. The third alternative, interfacing with the governor’s office, seems to have a moderate level of effectiveness. The ability for someone in the governor’s office­ with sympathetic leanings to Platypus’ cause­ to enact change seems plausible. However, the certification would be valid only in a single state. The efficiency of this plan of action also appears relatively low. It may require the hiring of a lawyer, in order to interface with the governor’s team, or travel to meet with the governor in the state capital

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(although local branches could likely accommodate a visit). The fourth alternative, engaging with congress members, is of uncertain effectiveness. It is unclear how much engagement with Congress members will affect the decision of EPA. Thus, even if Platypus can convince Congress members to support autonomous robotic boats, it is not certain that it will result in a federal level certification from EPA. However, the efficiency of this alternative is high, because Platypus can contact office of government relations at Carnegie Mellon University to help arrange meeting with some Congress members. With support from Congress members, the process to approve new certification would also not take a long time. The status quo and four alternatives are compared on the following chart:

Table 6.1: Evaluation of Strategies for Gaining EPA Certification

Alternative Effectiveness Efficiency

Status Quo: EPA personal interfacing + ­

Option 1: Work with EPA + +

Option 2: Partner with company, work with PA­DEP + +

Option 3: Interface with Governor’s office + 0

Option 4: Engage with Congress members 0 +

When comparing these factors, it is uncertain which alternative is better between options 1 and 2, due to the moderate chance of both effectiveness and efficiency. Nonetheless, from our analysis, proposing certification directly to the EPA (option 1) is the most promising alternative, because the effectiveness is relatively higher as the certification in this option will be nationwide. 6.2 Incentive to Test The desired outcome for Platypus, in this domain, is the enactment of non­market incentives to encourage more rigorous water testing­ i.e. more data points over a larger area or more frequency required to monitor water quality. In this section both the effectiveness and efficiency of this goal are evaluated, for each of the proposed strategies, and the status quo. The status quo, waiting for EPA to incentivize testing, is of low effectiveness for achieving this goal. Since this method does not require much time or financial input, the efficiency is moderate, in that the team can focus their resources on other areas, but the likelihood of regulatory change in favor of Platypus is unchanged. The first option, supporting regulations to require that testing be conducted with more data points (the service that Platypus provides), is of high effectiveness. This strategy pushes for regulations to the exact effect that would benefit Platypus. One concern with strategy, however, is that it requires either companies or the government to pay for this increased testing. Therefore, the efficiency is relatively low, because the possible alienation of potential clients (corporations) is a cost to Platypus and the required

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effort to push these rigorous regulations would be considerable. The second option, supporting tradeoffs or leniency for companies, is likely of high effectiveness. By tradeoffs, it is meant that the company could trade higher testing standards in one are for lower testing standards in another. As an example, the company could perform less frequent testing, in exchange for higher volume of data points per test. The efficiency of this option is also high, because the opportunity costs (the danger of creating adversaries) are low, since the benefits to both environmental activists (who support more thorough corporate testing of pollution) and corporations (who want to minimize cost of testing) outweigh the drawbacks associated with implementation.

The third option, partnering with environmental groups, is likely of questionable effectiveness in achieving the Platypus team’s goals. Partnering with environmental groups is likely to raise awareness of the technology and support for larger data testing, within the environmental community. However, support from the environmental community leads to unpredictable outcomes. Policymakers may draw attention to this issue but it may not result in any tangible incentives for Platypus’ intended customers. The efficiency of such a plan is high, however, because of the low costs associated with simply interfacing with environmental supporters. Many environmental groups have high tendencies to support Platypus so that it do not need to put much effort to gain support from environmental groups. The status quo and three alternatives are compared on the following chart:

Table 6.2: Evaluation of Strategies for Incentivizing Testing

Alternative Effectiveness Efficiency

Status Quo: Await federal regulation ­ 0

Option 1: Push for regulation that increases test data volume + ­

Option 2: Push for leniency or tradeoff regulation + +

Option 3: Join forces with environmental groups 0 +

When comparing these factors, pushing for incentivizing regulation appears to be the most promising option. By incentivizing regulations, it is meant: regulations that provide tradeoffs or leniency (option 2), which offers reduction in fines for infractions found outside of EPA testing. 6.3 Financial Opportunity The desired outcome for Platypus, in this domain, is finding a permanent source of funding for the business. In this section both the effectiveness and efficiency of this goal are evaluated, for each of the proposed strategies, and the status quo. The status quo is to gain funding from university grants, small private fish farms and small corporation investments (e.g. Port of Pittsburgh). The effectiveness of this plan is moderate, since it has sustained the business to this point. Platypus has formed a company, though, so it is looking to expand funding opportunities and move away from university funding. As a result, other options must be explored. The efficiency of the status quo is moderate, as resources are not spent looking for new outlets, but funding

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stagnates. The first option, looking for funding directly from the EPA, is of high effectiveness. Funding from the EPA would be for conducting monitoring programs across the state (PA) or across the country. The effectiveness is high because of the large size of the potential contract. The efficiency for this option is low, because the time and financial resources necessary to attract such a contract would be large. The second option, looking for corporate sponsor, is of high effectiveness. This option covers both corporate funding to satisfy EPA testing requirements, and corporate funding for testing over and above regulations (possibly for PR reasons). The efficiency of this strategy is also high, because the time and funds required to gain a corporate contract are lower than dealing with a government entity. Once incentives are created, the corporate market for Platypus should be both effective and efficient. The third option, seeking USAID funding, is of high effectiveness. Platypus has already proved its effectiveness in flood mitigation circumstances. Funding from USAID, for performing similar work could be a large­ USAID yearly flood funding is in the tens of millions of dollars­ and steady­ flooding occurs every year, somewhere [USAID website, usaid.gov]. The efficiency of this strategy is also high, because USAID has a formal process for applicants for funding or grants in place. Platypus can apply with that process to access to funding or make unsolicited proposals through the provided channel. Thus, the effort and resources needed to pursue this option is relatively low. The fourth option, collaboration with NGOs, is likely of moderate effectiveness. These organizations, such as Greenpeace and World Wildlife Foundation (WWF), are likely to support the environmental benefits of Platypus technology. The effectiveness is moderate because of the limited budgets of such organizations. The efficiency of this option is likely high, because of the support that these organizations likely already show for environmental testing technology. Thus, the time and finances needed to convince the groups is lower than for other potential options. The fifth option, working for private fish and shrimp farms, is of moderate to low effectiveness. Platypus has already demonstrated performance in this market. The relatively low effectiveness of this option results from the fact that it is a small potential market, with relatively small areas to monitor­ when compared to larger environmental and waterway monitoring outlets. The efficiency is high though, because of the proven efficacy of Platypus in the market, and the good alignment between Platypus technology (hypoxia and toxin testing) and the fish farming sector. The status quo and alternatives are evaluated in the following chart (next page):

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Table 6.3: Evaluation of Strategies for Gaining Sources of Funding

Strategy Effectiveness Efficiency

Status Quo: University funding/ small orders 0 +

Option 1: EPA funding + ­

Option 2: Corporate sponsor + +

Option 3: USAID funding + +

Option 4: NGO partnership 0 +

Option 5: Aquaculture market 0 +

When comparing these factors, seeking corporate funding (option 2) and USAID funding (option 3) appear as the most promising strategies.

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7. Bargaining Context and Spreadsheet

In this section, alternate strategies will be appraised, in terms of responsiveness and equity. Responsiveness refers to the extent, to which policy actors will support the strategies. Equity refers to the consequences of those strategies for concerned parties­ including the public, customers and competitors. The customers discussed here are industries or other polluters who need to follow EPA compliance standards. The competitors discussed here are the manual water monitoring service companies. For each strategy, the responsiveness and equity will be judged on a relative scale, with three grades possible. When used to rank responsiveness, the scores represent the following: Plus (+): Strategy is likely to be supported Minus (­): Strategy is likely to be opposed Even (0): Strategy may, or may not, be likely to be supported When used to rank equity, the scores represent the following: Plus (+): Strategy offers positive consequences to those parties Minus (­): Strategy offers negative consequences to those parties. Even (0): Strategy may, or may not, offer consequences to those parties. 7.1 EPA Certification The desired outcome for Platypus, in this domain, is to gain EPA certification for their testing platform and procedure. In this section both the responsiveness and equity of this goal are evaluated, for each of the proposed strategies and the status quo. The status quo, discussing with a member of the EPA, has questionable outcomes. Although Platypus’s technology will be beneficial to pollution control, it may increase the financial burden on companies and other polluters. Because of unclear advantages to these parties, the members of EPA may or may not work further on certification standards. Hence, the responsiveness can be either positive or negative. Also, with the current situation, the equity to the public is negative, since the public has limited data about the environment. For customers, the equity is negative since they have limited alternatives to monitor water. The competitors can keep market share from Platypus. Therefore, the equity of competitors will be positive. Regarding responsiveness, Platypus is likely to get support from EPA, since Platypus’s technology provides a more detailed picture of water condition, which can help to manage pollution more effectively. Some Congress members, who are interested in environmental issues, may also be supportive of Platypus’s technology, for similar reasons. At the same time, other institutions may not be as interested in environmental issues as the EPA or environmentally­concerned members of Congress. So, the responsiveness is positive for working with EPA (option 1) and engaging with Congress members (option 4) and neutral for other options. All of the four alternatives (working to get the certification with EPA, partnering with company to submit data to PA­DEP, working with governor’s office, and engaging with Congress members) have similar equity, because the certification they seek work in the same manner, just through different avenues. The equity for the public is positive, because it leads to more effective pollution control. The equity of customers is also positive, since the customers will have more water testing service providers to choose from and the competition tends to decrease the price of services. The equity of competitors is negative

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since the competitors will face more intense competition. The status quo and three alternatives are compared on the following chart:

Table 7.1: Evaluation of Strategies for Gaining EPA Certification

Alternative Responsiveness Equity (public)

Equity (customers)

Equity (competitors)

Status Quo: EPA personal interfacing

0 ­ ­ +

Option 1: Work with EPA + + + ­

Option 2: Partner with company, work with

PA­DEP

0 + + ­

Option 3: Interface with Governor’s office

0 + + ­

Option 4: Engage with Congress members

+ + + ­

When comparing these factors, all alternatives are better than the status quo. However, working with the EPA (option 1) and engaging with Congress members (option 4) appear to be the most promising. 7.2 Incentive to Test The desired outcome for Platypus, in this domain, is the enactment of non­market incentives to encourage more rigorous water testing­ i.e. more data points over a larger area. In this section both the responsiveness and equity of this goal are evaluated, for each of the proposed strategies and the status quo. The status quo, waiting for EPA to incentivize testing, is not likely to enact change, as the attention of public and policymakers in this issue is small. Thus, the responsiveness is neutral. Without incentive, it is unlikely that the public will gain maximum benefit from the capability of Platypus’s technology ­ so, the equity is negative. The customers are not impacted by the current status, so the equity is neutral. For the competitors, the equity is positive because it will be hard for Platypus to penetrate their market. For responsiveness, the push for more test data (option 1) will likely gain support from some policymakers who want more environmental data. It will likely be opposed by those who do not want to impose more burden on the business sector. So, the responsiveness is neutral. Proposing leniency or tradeoffs (option 2) is more likely to gain support from policymakers, because it also offers benefit to the business sector, making the responsiveness positive. For the partnership with environmental groups (option 3), the environmentalists would tend to support this action, since they would like to see a more rigorous standard of water monitoring. Thus, the responsiveness is positive.

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Equity for the public is positive only in option 1, because the proposed law will force all companies to monitor for graphical data­ leading to better pollution control. Conversely, options 2 and 3 have uncertain outcomes. Although these options could lead to more monitoring for graphical data, without a method of enforcement it is possible that only a small number of the companies will monitor for graphical data. As for the equity of customers, since the proposed regulation (option 1) demands all customers to use the graphical data services, it may prove more costly; so, the equity is negative. The second option results in more choices for customers to choose from and possibly lower prices. In that case, the equity for customers is positive. Partnering with environmentalists (option 3) may negatively impact the firm's’ reputation with corporate interests. Therefore, the equity of this option is negative. The status quo and three alternatives are compared on the following chart:

Table 7.2: Evaluation of Strategies for Incentivizing Testing

Alternative Responsiveness Equity (public)

Equity (customers)

Equity (competitors)

Status Quo: Await federal regulation

0 ­ 0 +

Option 1: Push for regulation that increases test data volume

0 + ­ ­

Option 2: Push for leniency or tradeoff regulation

+ 0 + 0

Option 3: Join forces with environmental groups

+ 0 ­ 0

When comparing all these factors, pushing for rewarding regulation (option 2) appears to be the most promising option. 7.3 Financial Opportunity The desired outcome for Platypus, in this domain, is finding a permanent source of funding for the business. In this section both the responsiveness and equity of this goal are evaluated, for each of the proposed strategies and the status quo. The status quo is funding from university grants, small private fish farms and small corporate investments (e.g. Port of Pittsburgh). The responsiveness is neutral, since Platypus currently does not induce much response from targeted customers. Platypus can contribute to its customers by offering low cost monitoring services for large areas, but with a relatively small number of services currently beig provided, the impact to the public and competitors is quite limited. Therefore, the equity is positive for customers and neutral for public and competitors. Regarding the responsiveness of the 5 options, gaining fund from USAID (option 3) is the only one with a positive responsiveness rating. Given that USAID has an existing funding program for these kinds of

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projects, there is a clear path for Platypus to follow in seeking funding. For the other options, there is little funding or original intent to develop a water monitoring robot, thus the possibility of them supporting Platypus is unlikely. The responsiveness is neutral for other options. All options, excluding the aquaculture market (option 5), make contributions to the public, because they offer more water quality data, which aids in pollution control, assists in exploring animal habitats and in turn improves quality of life. Hence, the equity for the public is positive. The opportunity in aquatic animal farms will not transfer much benefit to the public, so the equity is neutral. Every option offers benefits to its customers, as Platypus can help them monitor water in affordable and novel ways. Therefore, the equity for customers in all alternative strategies is positive. As per equity of competitors, EPA funding and corporate sponsorship (option 1 and 2) could potentially take the market opportunity from other water monitoring companies, so the equity is negative. For the other options, Platypus works in new markets where its competitors do not exist, so the equity is neutral.

The status quo and alternatives are evaluated in the following chart:

Table 7.3: Evaluation of Strategies for Gaining Sources of Funding

Alternative Responsiveness Equity (public)

Equity (customers)

Equity (competitors)

Status Quo: University funding/small orders

0 0 + 0

Option 1: EPA funding 0 + + ­

Option 2: Corporate sponsor 0 + + ­

Option 3: USAID funding + + + 0

Option 4: NGO partnership 0 + + 0

Option 5: Aquaculture market 0 0 + 0

When comparing these factors, seeking USAID funding appears as the most promising strategy.

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8. Strategy

After comparing the various alternatives, in terms of effectiveness, efficiency, responsiveness, and equity, we propose that Platypus adopt the following strategy: 8.1 Gaining EPA certification To achieve EPA certification for their testing platform and strategy, Platypus should work with the EPA to demonstrate the boat’s ability to comply with, or exceed, the current testing methods. The methods for testing are outlined in the Clean Water Act (CWA), and compliance requires a number of requirements for the boat and the testing method. First, Platypus must demonstrate that their boat complies with the articles expressly required by the EPA, for water testing. Second, they must demonstrate that the results of their tests agree with those of the conventional tests. 1. Although the Platypus boat is a testing station, made of sensors, some parallels can be drawn to EPA’s guidelines for automatic samplers. The necessary requirements for automatic samplers, under current CWA practice, are as follows [EPA SESDPROC­306­R3]: “ 1. Sampling Equipment must be properly cleaned, to avoid cross­contamination

2. No metal or plastic parts of the sampler are to come into contact with the water source, when parameters to be analyzed could be impacted

3. Automatic sampler must be capable of proper refrigeration during the sampling period 4. Automatic sampler be able to collect a large enough sample for all parameter analyses 5. Sample aliquot must be 100 ml, if a peristaltic pump is used 6. The automatic sampler should be capable of providing a lift of at least 20 feet and the sample

volume should be adjustable since the volume is a function of the pumping head 7. The pumping velocity must be at least 2 ft/sec to transport solids and not allow solids to settle 8. The intake line leading to the pump must be purged before each sample is collected 9. The minimum inside diameter of the intake line should be 1/4 inch 10. An adequate power source should be available to operate the sampler for the time required to

complete the project. Facility electrical outlets may be used if available 11. Facility automatic samplers should only be used if 1) field conditions do not allow for the

installation of EPA sampling equipment, and 2) the facility sampling equipment meets all of the requirements detailed above ”

The first requirement is of the most concern for Platypus, since their sensors are placed in the water and collect continuous data. The EPA may be concerned that moving the sensors through water may result in residual contaminants remaining on the sensor. This is a question that Platypus would need to address. The second requirement is also of some concern to Platypus, since their sensors are in contact with the water. The sensors that Platypus uses are EPA certified, though, so the Platypus team should be able to contend that they will not impair the quality of the sample. Requirement number 3 is not applicable, because its purpose is simply to ensure that the quality of the water sample remains as close as possible to the quality at the time and location of extraction. Since the sensors on a Platypus boat test the water in real time, the requirement is not applicable. The following several requirements, numbers 4 through 9, are also not applicable, because Platypus’ apparatus uses sensors, instead of collectors with pumps. Requirement 10 is applicable, because of Platypus’ intention to use solar charging stations. This requirement would likely allow the use of a solar charging station, but some clarification would be needed. The similar situation of automatic samplers should be drawn upon by the Platypus team, in working with the EPA towards

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certification. In addition to these requirements of the automatic sampler, some additional requirements would be likely of an autonomous boat that makes use of sensors. For instance, it would need to be demonstrated that the Platypus sensors remain in the water during testing. Certain quality control studies, in addition to video surveillance or human monitoring, could provide the required proof of the sensor’s location. 2. The Clean Water Act discusses two aspects of water testing. First, there is a baseline testing phase­ where the EPA and local regulators determine whether waters need cleaning up. In this phase the regulators, state and federal authorities, determine what standards need to be enacted and enforced. During this stage, Platypus should run tests in parallel with the EPA. This would allow them to demonstrate the efficacy of their testing method, without having to have prior EPA certification. A prescribed quality control plan could be completed, with positive results demonstrating efficacy to the EPA. Since the Platypus data is timestamped, it can be compared to traditionally tested samples. A successful showing in this demonstration would likely provide the EPA with the necessary proof that the system is reliable, and ready for certification guidelines. Platypus could suggest EPA to edit the automatic sampler guidelines to be fit with autonomous robotic boats or to draft a new guidelines for autonomous robotic boats. 8.2 Offering incentive to use Platypus’s water quality monitoring

To attract more customers in EPA compliance market, Platypus should collaborate with EPA further to offer leniency in the regulation for its customers as they work more aggressively to monitor environmental impacts from their operations. This strategy can be executed in line with the existing incentives programs of EPA. One of the incentives program is EPA’s audit policy. The regulated entities who voluntarily discover, promptly disclose to EPA, expeditiously correct, and prevent recurrence of future environmental violations may be eligible to significant reductions in both civil and criminal penalties. Generally, civil penalties under the environmental laws have two components, an amount assessed based upon the severity or “gravity” of the violation, and the amount of economic benefit a violator received from neglecting to comply with the law [EPA website, EPA’s Audit Policy, epa.gov]. According to the EPA’s audit policy, entities that satisfy the following conditions are eligible for Audit Policy benefits. “ 1. Systematic discovery of the violation through an environmental audit or the

implementation of a compliance management system. 2. Voluntary discovery of the violation was not detected as a result of a legally required

monitoring, sampling or auditing procedure. 3. Prompt disclosure in writing to EPA within 21 days of discovery or such shorter time as may

be required by law. Discovery occurs when any officer, director, employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred.

4. Independent discovery and disclosure before EPA or another regulator would likely have identified the violation through its own investigation or based on information provided by a third­party.

5. Correction and remediation within 60 calendar days, in most cases, from the date of discovery.

6. Prevent recurrence of the violation. 7. Repeat violations are ineligible, that is, the specific (or closely related) violations have

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occurred at the same facility within the past 3 years or those that have occurred as part of a pattern at multiple facilities owned or operated by the same entity within the past 5 years; if the facility has been newly acquired, the existence of a violation prior to acquisition does not trigger the repeat violations exclusion.

8. Certain types of violations are ineligible such as those that result in serious actual harm, those that may have presented an imminent and substantial endangerment, and those that violate the specific terms of an administrative or judicial order or consent agreement.

9. Cooperation by the disclosing entity is required.”

The entities that meet all the requirements will face no gravity­based penalty. Even if an entity fails to meet the first condition i.e. systematic discovery, it can still be eligible for 75% gravity­based penalty mitigation, and a recommendation for no criminal prosecution of the violations against the entity [EPA website, EPA’s Audit Policy, epa.gov]. Platypus can offer its customers to integrate its service with the compliance management system to help them meet the first four requirements: systematic discovery, voluntary discovery, prompt disclosure, independent discovery and disclosure. In long term, Platypus might offer an entire compliance management program instead of only water monitoring to fulfill all requirements.

8.3 Gaining USAID funding Platypus can seek funding opportunity from U.S. Agency for International Development (USAID). USAID is U.S. government agency that provide assistance to foreign countries. One of its contribution is the flood control. It had spent $68.7 million to protect properties and lives from flood [USAID Budget Report FY2015]. Some of this expenditure would be related to flood water quality monitoring. Also, it supports the development in the “water and sanitation” and “environment and global climate change” sector. Therefore, Platypus, who provide services in flooded and polluted area, has a high opportunity to get funding from USAID. There are a number of ways for Platypus to get involved with USAID:

1. Development Innovations Ventures ­ an open competition that offer funding for breakthrough, cost­effective solutions to the global challenges

2. Grand Challenges for Development (GCD) ­ a partnership program of USAID to work collaboratively with companies, foundations, NGOs, universities, and other agencies.

3. Unsolicited Proposals & Grant Applications ­ a channel of USAID that receive external ideas that can contribute to the society.

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