MEMORANDUM

TO:		Public Record for the NPDES Electronic Reporting Rule
		EPA Docket Number EPA-HQ-OECA-2009-0274 (www.regulations.gov)	

FROM:	Carey A. Johnston, P.E.
            USEPA/OECA/OC
            ph: (202) 566 1014
            johnston.carey@epa.gov

DATE:		31 August 2012

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SUBJECT: 	Adoption rates of Permittees Where States Have the Option for E-Reporting DMRs [DCN 0027]
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Status of States Regarding e-Reporting of DMRs

      A number of states authorized by EPA to implement the NPDES program have switched from paper to electronic collection of Discharge Monitoring Reports (DMRs). EPA has asked a number of states about the participation rate of NPDES regulated entities in the state's electronic collection of DMRs as part of its regular set of calls with states. EPA has learned that migration to e-reporting of DMRs is not uniform across the states. EPA is aware of only two states (Ohio, West Virginia) that have mandated that NPDES regulated entities submit their DMRs electronically. 
      
      Below are the participation rates of NPDES regulated entities in the state's electronic collection of DMRs. These are participation rates are preliminary and apply to facilities individual permits that are required to submit DMRs. 
      
         *       California  -  70% of all permittees designated as majors
         *       Kansas  -  10% of all permittees designated as majors
         *       Louisiana  -  10% of all permittees
         *       Maine  -  85% of total
         *       Massachusetts  -  35% of total
         *       Mississippi  -  35% of total
         *       North Carolina  -  2% of total
         *       Ohio  -  100% of total
         *       Virginia  -  40% of total
         *       West Virginia  -  85% of total
         *       Wyoming  -  90% of total

      Two states (New Jersey and Vermont) have indicated they are not moving toward electronic reporting at this time. Thirteen states (Alaska, Arizona, Georgia, Iowa, Missouri, Montana, Nebraska, Nevada, New York, North Dakota, Oregon, Rhode Island and South Carolina) are in some stage of planning for electronic reporting.
      
      There is no information available on the territories, but only the Virgin Islands has received authority to administer the NPDES program.  The other territories are under EPA permitting authority. The remaining states and the District of Columbia have implemented some form of electronic reporting for DMRs.  No adoption rate information is available for the other states at this time


