EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA May 31, 2012 General Session for the

1. 5/30/11 EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA May 31, 2012 General Session for the Exchange Network National MeetingPhiladelphia, Pennsylvania

2. Outline • E-Reporting is Here • Opportunity • Savings and Benefits • Agency Electronic Reporting Plans • Challenges

3. E-Reporting Has Arrived • E-Reporting is here, for example: • Taxes • Stocks, bond and mutual funds • Mortgage/loan applications • Medical • Job applications • Retail purchases • Staying in the paper world not an option.

4. Environmental Opportunity • Advances in emissions/pollutant monitoring and information technology are likely to vastly change environmental protection. • This will give industry, government and public new and better information on pollution sources and environmental conditions. • This will create new incentives to reduce and prevent pollution. • Electronic reporting is critical component in making this happen.

5. What is electronic reporting for environmental regulations? • E-reporting is not just emailing a file to the government. • E-reporting is a system: • Web tool or smart form, (e.g. , TRI-ME), which: • Prevents errors, reuses data, performs calculations. • Provides compliance assistance. • Provides quick confirmation of submission and acceptance. • National data standards, including electronic signature identity validation for CROMERR • System to accept, integrate and analyze the data.

6. Cost Savings • Electronic reporting reduces costs associated with all steps in paper reporting: • Creation of paper report • Mailing • Receipt by government • Manual data entry into system • Subsequent error correction from: • Submitted paper form • Created by government from manual key punching. • This is a major annoyance to regulated entities.

7. Program Benefits should reduce pollution • With more complete, higher quality, and timely data, government can more effectively prioritize regulation development, permitting, monitoring and enforcement. • Public transparency enhanced. • Transparency tools may be non-government as well, apps. • Regulated entities will know their data is immediately accessible and this will increase incentive for them to comply.

8. Examples of E-Reporting in Environmental Protection • NPDES E-Reporting: • Improves quality and utility of NPDES program data by ensuring that the information submitted to EPA and the states is timely, accurate, complete, and nationally consistent. • Automatically identify some violations and assess their severity • TRI-ME: • e-reporting promotes more accurate reporting with fewer facility errors and can allow regulators to more efficiently evaluate compliance • Acid Rain program: • Standardized e-reporting helped contribute to the Program’s “largest quantified human health benefits of any federal regulatory program implemented in the last 10 years.

9. Background on Agency E-Reporting Activities • EPA’s Final Plan for Periodic Retrospective Reviews of Existing Regulations, August 2011, made public commitment to advance electronic reporting. • Agency created an Electronic Reporting Task Force in December 2011 to implement. • Co-chaired by Deputy Assistant Administrators for Enforcement (OECA), Environmental Information (OEI), andRegion 1 Deputy Regional Administrator. Members include managers from the 4 media program offices, Region 5, Office of General Counsel and Office of Policy. 9

10. Task Force Key Responsibilities • Establish Agency policy for electronic reporting as “default” in new regulations. • Identify Agency priority for converting important existing paper reports to electronic, and opportunities for consolidation/deletion of existing paper, and comprehensive plan to do this. • Do this in a “OneEPA” approach.

11. E-Reporting Agency Policy • Develop policy and implementing procedures/tools to establish electronic reporting as the “default” assumption in new regulations. This will address: • The types of data and format. • When new rules would allow or require paper reporting. • Standard exemptions from mandatory electronic reporting; • The efficient use of agency exchange services (e.g., registration, CROMERR, security, CDX) and data standards; • How to leverage agency resources for reuse and expansion of IT tools, interfaces, and services.

12. Converting Important Existing Paper Reporting to Electronic • The Task Force requested Programs and regions to identify their most important paper reports for electronic conversion, and proposals for reducing or streamlining existing paper reporting. • The Task Force will review submissions and recommend a priority Agency list • Recommendations may include how to streamline regulation changes, including use of omnibus rules.

13. Opportunity to be bold as we convert from paper to electronic: One idea - • Consolidate and convert to electronic the existing paper Financial Assurance reporting regulations under TSCA, RCRA-Corrective Action, RCRA-core, CERCLA and SDWA-UIC. • Perhaps standardize these programs and help ensure financial assurance funds will be available to perform cleanups. • Perhaps create one electronic reporting tool/portal and backend database to support FA reporting. • Perhaps modify all of these regulations via omnibus rule.

14. Key ChallengesResources • Electronic Reporting has great benefits: • more complete, timely and quality data improve government and industry performance and expand transparency • Long-term costs savings over paper processes. • But electronic reporting requires investment and operation and maintenance costs. • The cost savings are spread across regions, states and regulated entities, but the system development and operation costs are often centralized in EPA headquarters or in a state.

15. Key ChallengesResources: Third Party Vendor Software Tools • Vendors could build electronic reporting software for environmental programs. • Similar to IRS model (e.g., Turbo Tax, HR Block at Home) • Private vendors might build better front-end tools than states and EPA • EPA did proof of concept that validated this. • Need to develop systems and resources to do this.

16. Key ChallengesCentralization at EPA • EPA (OEI) currently does provide some centralized services for supporting electronic reporting, but we still have multiple, separate program specific tools. • Would fewer tools be more efficient and still allow us to meet program specific needs? • Need to streamline regulation development to convert to electronic via omnibus rules and common economic analysis tools.

17. Key ChallengesAddressing State Concerns • State readiness for electronic reporting varies considerably. • States generally support electronic reporting but concerned about investment costs. • Some states may use national EPA systems and tools to support electronic reporting. For example: • EPA front-end reporting tools (e.g., NetDMR, TRI-ME), or CROMERR service for identify proofing for electronic signature. • Back-end national data bases, such as ICIS-NPDES • States will need to extract data (outbound services)

18. Key ChallengesOpportunity • State EPA Environmental Information Exchange Network and CDX give us good foundation. • We will reach out to states to understand their concerns and to address them. • The challenge is to move to electronic reporting efficiently, and leverage already built systems and tools. • Assume we do not want to build and support 50+ electronic reporting tools for each environmental program.