Presentation on theme: "EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA May 31, 2012 General Session for the Exchange Network National Meeting Philadelphia,"— Presentation transcript:
EPA Plans for Moving Forward with Electronic Reporting David Hindin, US EPA May 31, 2012 General Session for the Exchange Network National Meeting Philadelphia, Pennsylvania 1 5/30/11
1. E-Reporting is Here 2. Opportunity 3. Savings and Benefits 4. Agency Electronic Reporting Plans 5. Challenges 2
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. 3
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. 4
E-reporting is not just ing 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. 5 What is electronic reporting for environmental regulations?
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.
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.
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. 8
9 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. 9
10 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, and comprehensive plan to do this. Do this in a “OneEPA” approach.
11 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 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 ◦ 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 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 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 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 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 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.