1. 1 The Resource Workgroup’s RIDE Data Entry Estimate Model Expanded Steering Committee Meeting December 11-12, 2006 Betsy Smidinger US EPA/OECA

2. 2 RIDE Data Entry Estimate Model: Development The underlying concepts for such a model were described and discussed in our June 2006 Expanded Steering Committee meeting in Washington, D.C. This model was developed by U.S. EPA Headquarters in consultation with the Resource Workgroup during the summer of 2006. The model was designed to better quantify the data entry resource implications associated with the entry of RIDE into ICIS-NPDES. The model does not (and was not intended to) address data collection.

3. 3 RIDE Data Entry Estimate Model: Complexity  The model takes into account number of data elements, frequency of data entry, and facility universes. It also accounts for data that is already being entered into PCS.  In the past six months, as U.S. EPA has sought greater accuracy, the model has become increasingly complex.  Today, there are hundreds of underlying assumptions (developed through consultations with subject matter experts) and calculations, with over 150 rows and over 30 columns of information, tied to groupings of RIDE.

4. 4 Yes In PCS? Data Group: Facility Direct User Example Subgroup: Basic Information Facility Universe X # Data Elements X Frequency Estimated data entry resources for the Facility Basic Information elements - (# facilities X data elements migrated from PCS) X Estimated seconds for data entry

5. 5 RIDE Data Entry Estimate Model: Example

6. 6 RIDE Data Entry Estimate Model: Adaptability and Uses  Although the primary purpose of the model has been to better quantify data entry resource implications, the model has also been adapted to: Compare relative data entry estimates for various program areas and permit types; Estimate data entry for individual States; and Inform decisions regarding possible proposals to address State concerns.

7. 7 RIDE Data Entry Estimate Model: Key Revisions As a result of a series of meetings with subject matter experts at U.S. EPA (Headquarters and Regions), U.S. EPA has made various revisions to the model, including: Changes to the RIDE list (discussed previously) Changes to national universe estimates and sub-division of these universes; Changes to estimated inspection frequencies for various program areas and permit types; and Changes to DMR-related assumptions.

8. 8 RIDE Data Entry Estimate Model: Universe Changes  As an example of universe changes, EPA broke out separately the number of approved local pretreatment programs (n=1464) and the number of POTWs covered by approved programs (n=1605).  Such a distinction is useful in the model because, although facility information would be expected for all “covered” POTWs, the approved programs (rather than the “covered” POTWs) would be the recipients of pretreatment audits and pretreatment inspections.

9. 9 RIDE Data Entry Estimate Model: Inspection Frequency Changes  The model now incorporates the inspection frequencies identified in the most recent draft of the NPDES Compliance Monitoring Strategy. Although this strategy is still draft, it may provide the best available estimate of the projected inspection frequencies for various program areas and permit types. The inclusion of these inspection frequencies represents inspection GOALS, rather than the ACTUAL inspection frequencies. Therefore, the model likely produces an OVERESTIMATE in terms of data entry.

10. 10 RIDE Data Entry Estimate Model: DMR-related assumptions  Several changes were made to DMR-related assumptions such as average number of outfalls, limits, and values expected for individual and general permits. For example: Baseline monitoring requirements for the stormwater industrial universe  These facilities had previously been grouped with traditional permits under a monthly monitoring assumption.  This has now been changed to reflect a more realistic expectation of about 2 reports per year.

11. 11 RIDE Data Entry Estimate Model: Latest Results --- Average FTEs per State  Based upon revisions made to the model since August 2006, the model now estimates that the average number of FTEs needed per State per year for RIDE data entry would be 1.8 FTEs.  The revised model estimate is approximately 45% of the estimate from the model in August 2006 (i.e, 1.8 FTEs compared to 4.0 FTEs).

12. 12 RIDE Data Entry Estimate Model: Latest Results --- State-Specific Results  During the summer, the model was used to calculate State- specific FTE results for the following nine States: Arkansas, Delaware, Georgia, Iowa, Mississippi, Nebraska, New York, Oklahoma and Utah.  U.S. EPA has not yet had an opportunity to recalculate the State-specific results based upon the revised model; however, if particular States are interested in such information, U.S. EPA is willing to work with the States to complete such calculations.

13. 13 December EPA Model Estimate of 1.8 FTEs.

14. 14 RIDE Data Entry Estimate Model: Latest Results ---Data Entry Slices Note: Full Circle represents 1.8 FTEs per State per year (based on December 2006 model)

15. 15 Notes

16. 16 RIDE Data Entry Estimate Model: Latest Results --- Special Program Areas

17. 17 RIDE Data Entry Estimate Model: Latest Results --- Summary  U.S. EPA has made significant efforts to better quantify the RIDE data entry burden through refinements to the model and its assumptions.  The model now indicates that there is a total RIDE data entry burden of only 1.8 FTEs for the average State per year.

18. 18 RIDE Data Entry Estimate Model: Latest Results --- Summary (continued)  Data entry of DMRs (including stormwater industrial baseline monitoring information) constitutes almost 90% of the RIDE data entry.  The data entry associated with special program areas (including wet weather) constitutes less than 10% of all RIDE data entry.