EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA May 31, 2012 General Session for the Exchange Network National Meeting May 29 – June 1, 2012 Philadelphia, Pennsylvania 1

1. E-Reporting is Here 2. Agency Electronic Reporting Task Force and Priority Goal 3. Key Challenges 2

 E-Reporting is no longer a future event; it is here.  It is happening across our economy, for example:  Taxes  Stocks, bond and mutual funds  Mortgage/loan applications  Medical prescriptions  Retail purchases 3

 E-reporting is not ing a file to the government.  E-reporting is a system: ◦ Smart form (web tool, App?) that guides regulated entity in reporting (e.g., TRI-ME, TurboTax)  Prevents errors, reuses existing data, perform calculations and provide compliance assistance.  Rapid confirmation of submission and then cceptance. ◦ National data standards, including identity proofing for CROMERR ◦ Data system to accept, integrate and analyze the data. 4

 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. 5

6  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), and Region 1 Deputy Regional Administrator. Members include managers from the 4 media program offices, Region 5, Office of General Counsel and Office of Policy. 6

7 1. Establish Agency policy for electronic reporting as “default” in new regulations. 2. Identify Agency priority for converting important existing paper reports to electronic, and opportunities for consolidation/deletion of existing paper. 3. Manage Priority Goal for Electronic Reporting.  Do this in a “OneEPA” approach.

8  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.

9  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.

10 ◦ 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.

11  Priority Goal statement (as submitted to OMB): ◦ Increase Transparency and Reduce Burden through e- Reporting. By the end of FY 2013, develop a plan to convert existing paper reports into electronic reporting, “establish” electronic reporting in at least four key programs, and adopt a policy for including electronic reporting in new rules. ◦ Priority Goal has quarterly milestones that are mix of policy, tools and proposed rule submissions to OMB.

12  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.

13  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.

14  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.

15  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)

16  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 do this 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.