Benefits of NPDES eReporting Tools for the Region 6 

Offshore Oil & Gas Permit

Overview

Using Regional funds of approximately $127,000, and headquarters staff
and contract funds of approximately $1.3 million, EPA Region 6 has
changed the Offshore Oil & Gas NPDES General Permit program from a state
of minimal support for a historically paper-based process to a fully
supported new electronic approach—requiring a fraction of the
previously-needed Full Time Equivalents (FTE).

Background

While EPA Region 6 was preparing to reissue the offshore general permit
for the deep water Gulf of Mexico region it was determined that, based
on events in the Gulf over the past several years, the Region needed to
develop a permit that would ensure that more comprehensive data would be
collected, and that compliance language would be strengthened. The goal
of Region 6 was to make certain that the environmental protections
extended to our sensitive gulf waters and coastal environments would be
felt for many years to come, as EPA would finally have a vehicle and
adequate tools to ensure environmental compliance in the Gulf of Mexico.


The updated monitoring requirements envisioned would almost triple the
data received and made available to EPA and the public. In addition, the
permit universe would cover approximately 36,000 facilities operating a
variety of exploration and production technologies for the extraction of
oil and gas deposits in the deep waters of the gulf. No other permit
would cover such a variety of changing operations, or the potential for
changing data sets at the same location. The Region 6 permit required
facilities to submit a Notice of Intent (NOI) to obtain permit coverage
and these NOIs needed to fit a variety of operations and outfall types
on a large scale.  

Recognizing that this new data collection effort would be a potential
issue with the offshore community, the Agency made the critical decision
to streamline the reporting process by developing an electronic
reporting tool. Through this tool, facilities can submit their data
electronically to EPA’s database (ICIS-NPDES). The electronic version
also automatically establishes the permittee in the ICIS-NPDES, and sets
up the permit limits and reporting requirements. 

Summary of Benefits

Since deploying the NPDES eReporting Tool (NeT) in October 2012, Region
6 has realized—and will continue to realize—a variety of benefits.
For example, staff are no longer required to manually enter data for
NOIs, Notices of Termination (NOT), or limits. Data entry has been
decreased by 1.5 FTEs, or approximately $225,000, by deploying the NeT.

In addition to current savings, the combination of NeT and NetDMR,
EPA’s online tool for electronic reporting of Discharge Monitoring
Report (DMR) data, will allow Region 6 to realize even greater savings
in the future. Region 6 would have needed an additional 3.5 FTEs, or
approximately $525,000 per year, to complete the work manually. By
completing this work electronically, the funds that otherwise would have
went to FTEs can be utilized for mission-critical projects. By March
2014, Region 6 anticipates seeing the most substantial cost savings. By
that time, over 2 million parameters (i.e., data elements) will be
entered into NetDMR per quarter.

Furthermore, Region 6 estimates that without deploying the electronic
reporting tools, NeT and NetDMR, data entry would have cost EPA
approximately $2.6 million during a five-year permit life cycle. The
projected benefits of electronic reporting are significant to EPA’s
bottom line.

In addition to the budgetary advantages of electronic reporting, NetDMR
has significantly improved data entry and data quality. In the past,
Region 6 was understaffed for data entry positions and was unable to
enter large amounts of DMR data. As a result, DMR data entry was
sporadic, thus creating data gaps in ICIS-NPDES and making it difficult
to detect violations and manage the program. This has changed with the
implementation of electronic reporting. The NeT and NetDMR programs have
also increased transparency for regulators, and for the public, while
providing better tools for ensuring compliance in a fair and reasonable
fashion.

Figure 1: NeT Forms Submitted by Certifier 

Oct 2012- July 2013

Figure 2: NeT Forms Submitted via Batch and 

Accepted by ICIS-NPDES 

Oct 2012- July 2013

Conclusion

The offshore permit process described here was the first General Permit
in the nation that established electronic submission of all data through
EPA’s electronic reporting tools (NeT and NetDMR). This effort, while
offering numerous benefits for both EPA and industry, has set the stage
for future electronic submittals of NOIs and other general permit forms
for other NPDES permits. 

Figure 3:  NeT Forms Signed by Certifier and 

Submitted to ICIS-NPDES  

Oct 2012- July 2013

 Assumes an average loaded FTE rate of $150,000

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Without deploying the electronic tools, data entry would have cost EPA
approximately $2.6 million during a five-year permit cycle.

