MEMORANDUM

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

FROM:	Rochele Kadish
            USEPA/OECA/OC
            ph: (202) 564 3106
      kadish.rochele@epa.gov

DATE:		26 November 2014

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SUBJECT:	Outreach for the Proposed NPDES Electronic Reporting Rule [DCN 0111]
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Overview of Proposed Rule

      EPA proposed a new regulation, the NPDES Electronic Reporting Rule (July 30, 2013; 78 FR 46005), that when finalized will substitute electronic reporting for paper-based reports, saving time and resources for permittees and states while improving compliance and better protecting the Nation's waters. The rule will require permittees and state and federal regulators to use existing, available information technology to electronically report information and data related to the Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit program in lieu of filing written reports (e.g., Discharge Monitoring Reports, annual compliance reports). The proposal will reduce the reporting burden currently borne by the states, allow better allocation and use of limited compliance and enforcement resources, improve overall facility compliance, and enhance transparency and public accountability by providing the public with timely information on potential sources of water pollution. EPA received 170 public comments on the 2013 proposed rule from a variety of stakeholder groups and most commenters were supporting of electronic reporting.

Summary of EPA Outreach Supporting the Proposed Rule

      Section VI of the proposed rule details EPA extensive outreach efforts prior to the proposed rule. EPA continued this outreach during the public comment period on the proposed rule. In particular, EPA held over 30 webinars and meetings with over 1,200 people to discuss the proposed rule (see Table 1).
      
      In addition to these 30 webinars and meetings, Environmental Council of States (ECOS), Association of Clean Water Administrators (ACWA) ask EPA in December 2013 to form a State Technical Workgroup to discuss issues related to the eRule.  This workgroup included representatives from over 25 states. The minutes from these workgroup meetings are located in the docket supporting this rulemaking (EPA-HQ-OECA-2009-0274).
      
      EPA is planning to publish a new Federal Register notice that will start a new public comment period, which will last 60 days. EPA will use this comment period to conduct additional stakeholders meetings to further discuss and refine particular aspects of the rule prior to promulgation. Outreach to stakeholders will continue to be supported through the NPDES Electronic Reporting Rule website; however, the website may be expanded to include more robust rule schedules as the rule nears promulgation, as well as additional rule documentation that may or may not be included as part of the formal docket library.Table 1: 	EPA eRule Outreach Activity Listing (July 2013  -  October 2014)
      
                                     Date
Outreach Activity
                                 July 24, 2013
Environmental Commissioners of States (ECOS) Data Management Meeting
                                 July 25, 2013
Agriculture Issues Forum
                                August 4, 2013
Association of Clean Water Administrators (ACWA) Meeting
                                August 6, 2013
National Agriculture State Departments Association (NASDA)
                                August 7, 2013
EPA Office of Congressional and Intergovernmental Relations
                                August 8, 2013
Farm, Ranch, and Rural Communities Federal Advisory Committee (FRRCC) FACA
                                August 27, 2013
Webinar for: State Environment and Agriculture commissioners/staff
                               September 4, 2013
Webinar for: National Association of Clean Water Agencies, Water Environment Federation, and National Rural Water Association
                              September 10, 2013
Webinar for: Regional Pretreatment Coordinators
                              September 11, 2013
Webinar for: Environmental Groups (Sierra Club, Water Keepers Alliance, Food and Water Watch, NRDC, River Network, Environmental Integrity Group and others)
                              September 17, 2013
Webinar for: Federal Water Quality Coalition (FWQC) and Corporate Environmental Enforcement Council (CEEC)
                              September 18, 2013
Department of Defense's Clean Water Act Services Steering Committee (CWA SSC)
                              September 18, 2013
Webinar for: State CAFO coordinators

                              September 19, 2013
Corporate Environmental Enforcement Council (CEEC) board meeting
                              September 24, 2013
Webinar for: Agriculture and CAFO regulated community
                               November 4, 2013
Webinar for: National Mining Association
                               November 12, 2013
Webinar for: State MS4 Industrial Stormwater Coordinators
                               November 13, 2013
Webinar for: State Pretreatment Coordinators
                               November 14, 2013
Webinar for: State Construction Stormwater Coordinators
                               November 14, 2013
South Dakota University Extension, Agriculture and CAFO regulated community
                               November 19, 2013
WEF small group meeting
                               November 19, 2013
Webinar for Stormwater permittees
                               November 20, 2013
Webinar for POTW permittees
                               November 21, 2013
ACWA small group meeting
                               November 26, 2013
American Petroleum Institute
                               December 3, 2013
Webinar for Stormwater permittees
                               December 3, 2013
ACWA State meeting on CROMERR
                               December 4, 2013
Webinar for POTW permittees
                               December 10, 2013
Colorado Ag/CAFO community
                               December 11, 2013
CSO EPA Region and State Coordinators
                                 March 3, 2014
Workshop: Industrial Wastewater College:  Fundamentals of Building and Maintaining a Pretreatment Program
                                April 10, 2014
Presentation at Region 3 Pretreatment Conference
                                 June 11, 2014
Associated General Contractors of America (AGC)
                                August 4, 2014
ACWA Summer Meeting
                               August 5-6, 2014
Presentation at Region 6 Pretreatment Conference
                              September 22, 2014
North Carolina Pretreatment Conference
                            Sept 27  -  Oct 1, 2014
WEFTEC National Meeting  -  New Orleans
                               Oct 6  -  8, 2014
NRWA Conference  -  Seattle
      
