ICIS-NPDES Defining What We Need I am representing direct user states and will attempt to define what we need from the ICIS-NPDES data system to effectively manage the NPDES program and its related subprograms. I will be discussing our needs from a very broad and high level perspective and will not be talking about the individual data elements needed to run an effective compliance program. Last week, I was fortunate enough to be able to talk to representatives of several of the other direct user states. I was able to obtain input regarding their concerns and their system needs as we go forward with ICIS-NPDES system implementation. Given that the direct user states will rely on ICIS-NPDES to manage the NPDES program in each of their states, they are, as a group, very supportive of the ICIS-NPDES project and want to see a successful implementation of this new system. Direct User States’ Perspective Michael Garretson

Direct User States 25 Direct User States (includes 9 partial) 5 USEPA Entered States & 9 Territories/Tribes 36% of Nation’s Majors 30% of Nation’s Minors

Data Entry Concerns/Needs Entry Burden Efficient Entry Screens: DMR, Permit, Inspections Ease of Use Categorize Facilities RIDE Review Automation: Permit Writers’ Program, eDMR/NetDMR It is not surprising that the increased Data Entry Burden is a major concern of the direct user States that have the most NPDES permittees. In Illinois, we have 276 majors and minors required to submit Discharge Monitoring Reports. Over the years we have strived to enter all DMR data received into PCS. In most years, we have been successful. However, depending on staffing resources, staff turn-over, and hiring policies, there have been times when we have had to set aside and not enter some of the minor DMRs. Permit coding has been especially challenging for us over the past couple of years. Our permit engineers have been under the gun to reduce the backlog of expired permits. While they have been very successful in doing so, my staff has struggled to keep up with coding and entering the permit limits and other permit requirements into PCS before these permits become effective. Timely and accurate entry of the permits into PCS is absolutely critical for the data management systems to work properly. You may be asking yourself, “Why is he talking about workload problems with PCS when this meeting is supposed to be about ICIS-NPDES?” Here’s the reason and the bottom line: If ICIS-NPDES is only as efficient as the current PCS for data entry of permit limits, DMR data, and inspections we are still going to experience problems meeting the data entry requirements of the PCS policy statement as it stands today. We are all hopeful that ICIS-NPDES will be much more efficient than PCS, however, until that it proven to be the case, there should be no increase in the data entry requirements imposed on the states. If for some reason the unthinkable happens and the new system is not as easy to use and is less efficient for data entry than the current PCS, then the new system needs to be fixed, before it is placed into production. The PCS system is over 20 years old. We do not know how long the ICIS-NPDES system will be used. Taking the necessary time now to ensure the new system works well will payoff during the coming years. Some other things that can be done to reduce the data entry burden include: Ease of Use - Allow users to copy permits with their permitted features and limits to minimize the data entry associated with permit issuance and renewal. I know……, this was a user requirement that got put on the back burner because of funding and implementation deadline concerns. That does not change the fact that it is still an important user need that would greatly assist the direct user states in reducing the data entry burden associated with permit coding. Categorize Facilities – We need to determine what subsets of facilities and permits are the most important to track in ICIS-NPDES. I am suggesting that there may be groups of facilities that do not warrant tracking in ICIS-NPDES. In other words, keep the major/minor concept but include priority facilities from the other NPDES subprograms such as CAFO and Stormwater. It’s looking like we will be issuing approximately 150,000 NPDES permits to individual homeowners in Illinois that have surface discharging treatment systems. This is a good example of a group of permits that, In my opinion, should be excluded from being required in ICIS-NPDES. RIDE Review - The Required ICIS-NPDES Data Element list needs reviewed with the objective of reducing the number of required data elements to a minimum. The required data elements need to be limited to those that are necessary for USEPA to answer the questions that are being asked of them. Automation: Permit Writers’ Program, eDMR/NetDMR – The data entry burden could be further reduced by developing software modules that distribute the data entry to many individuals. For example, permit writers could use a software module to help them draft permits and the same program could automatically transfer the permit limits and other requirements to ICIS-NPDES. A permit writing module has been needed for a long time. Another example would be electronic DMR reporting. Many states want their permittees to report DMRs electronically. It is necessary that these software modules be developed and that they become a permanent part of the ICIS-NPDES System.

Additional Concerns/Needs PCS - ICIS Migration Staff Training DMR Preprinting Funding PCS - ICIS Migration – We need our permits, along with their limits and other requirements, to be properly migrated into ICIS-NPDES. We will not have the time to check that each permit was migrated properly. Staff Training – This was another big concern. We are hopeful that ICIS-NPDES will be easy enough to use so that records management staff can process FOIA requests on their own, Compliance staff and Permit writers can look up DMR data themselves, and field staff can enter the inspections that they have conducted into the system. In order to get to this point, a good deal of staff training will need to take place. Training will also be needed on a continuing basis as staff turnover occurs. The next concern is a need for a high speed process for DMR preprinting. This is important, especially for those states with large numbers of NPDES permittees that are required to submit DMRs. With ICIS – NPDES, states will be responsible for preprinting the DMRs for use by their permittees. We are currently preprinting our DMR forms using high speed line printers, however, some of the other states rely on NCC to generate the preprinted DMRs for them. It can take 2-3 working days to generate a normal size batch of our DMR forms using our line printers. We are hopeful that this process will be sped up significantly as we switch over to high speed laser printers for this task. Funding for Additional Staff – One state with 145 majors and 10,000 minors has studied the impact the proposed ICIS-NPDES policy statement would have on their staffing needs. Even though Missouri is already performing data entry for all of their major and minor facilities, they estimate that the requirements of the proposed ICIS-NPDES policy statement would increase their data entry workload by 15%. This translates into a need for an additional 6.5 FTE. They are counting on increases to the 106 program funds to pay for the additional staff.

Summary of Recommendations Focus on System, Ease of Use, and Efficiency – Not Implementation Deadlines Fix ICIS-NPDES System Problems Identified thru User Testing & Conversion Maintain Existing Data Requirements Until System is Optimized Form Workgroup to Categorize Facilities and Review RIDE