EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA

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

2. Discussion today • E-Reporting is Here • Agency Electronic Reporting Task Force and Priority Goal • Key Challenges

3. E-Reporting Has Arrived • 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

4. Electronic Reporting in Environmental World • E-reporting is not emailing 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.

5. 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.

6. 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. 6

7. Task Force 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. • Manage Priority Goal for Electronic Reporting. • Do this in a “OneEPA” approach.

8. 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.

9. 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.

10. 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.

11. Agency Priority Goal on Electronic Reporting • 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. 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.

13. 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.

14. 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.

15. 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)

16. 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 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.