UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

SEP 3 0 2013 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

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Assistant Administrators 

General Counsel 

Inspector General 

Associate Administrators 

Regional Administrators 

DEPUTY :\DMl.NlSfR:\ 1\iR 

We are establishing a new Agency-wide policy one-reporting that specifies in developing new 

regulations that we will start with the assumption that reporting will be electronic and not paper 

based. And we will use shared services to do this to the maximum extent possible. This Policy 

Statement is one important step forward in the Agency's larger E-Enterprise for the Environment 

Initiative. 

This action fulfills the Agency's commitment to institute electronic submissions in place of 

existing paper-based reporting to meet the Agency's regulatory reporting requirements. And it 

meets our commitment in the Agency Priority Goal forE-Reporting. The Policy embraces the 

Digital Government Strategy issued by the White House on May 23, 20122 which calls for the 

EPA to continue evolving its reporting systems to take advantage of new technology and 

improve transparency for all our stakeholders. 

More details on implementation of the attached Policy Statement will be set forth in internal 

implementing guidance from the Office of Policy in October 2013. 

Attachment 

cc: EPA Internal E-Enterprise Management Team. 

1 EPA's Final Plan for Periodic Retrospective Reviews. August 2011 (p. 6) 2 http://www. whitehouse.gov/sites/default/files/omb/egov/digital-govemment/digital-govemment-strategv.pdf 
Policy Statement on E-Reporting in EPA Regulations 

September 30, 2013 

The Policy ofthe U.S. Environmental Protection Agency (EPA) is to: 

1. Begin the regulatory development process with the assumption that all reporting will be 

electronic, unless there is a compelling reason to use paper reporting; 

2. Use, to the maximum extent practicable, common agency tools, information systems, and 

data sets forE-Reporting (i.e., shared services); 

3. Develop and use E-Reporting tools and processes that help regulated entities understand their 

regulatory reporting requirements; and 

4. Collaborate with States, local governments, tribes, and territories thru theE-Enterprise 

initiative to help enable the adoption ofE-Reporting and to harmonize the development and 

use of systems and tools to support it. As part of this collaboration thru E-Enterprise, EPA 

will work with states and others to identify and prioritize which existing paper-based 

programs should be transitioned to electronic reporting and how. 

EPA does not intend that this Policy will, by itself, change the federal and state roles in 

environmental programs. Any such changes in roles will be separately negotiated and agreed 

upon in the appropriate documents, such as program memorandum of agreements. 

This document is a statement of Agency policy and does not constitute a regulation. It is not 

intended, nor can it be relied upon, to create any rights enforceable by any party in litigation with 

the United States. 

Details on implementation of this policy in the Agency's Action Development Process (ADP) 

will be distributed shortly by the Office of Policy. 

BACKGROUND 

EPA believes this Policy will improve data quality and the ability of government agencies to 

manage environmental programs efficiently and effectively. E-Reporting will help increase 

transparency through data availability and encourage greater accountability of regulated entities 

and the government to the public. In addition, the Policy will result in more effective 

engagement with the regulated community, and can often reduce regulatory burdens, while 

enhancing collaboration among levels of government. 

This Policy is part of theE-Enterprise for the Environment initiative. E-Enterprise is a joint 

initiative between States and EPA to improve environmental outcomes and dramatically enhance 

service to the regulated community and the public by maximizing the use of advanced 

monitoring and information technologies, optimizing EPA and state operations, and increasing 

transparency. Moving from paper to electronic reporting is a key component ofE-Enterprise and 

this Policy sets forth the Agency's commitment to moving to electronic reporting. 
As EPA moves forward with electronic reporting, the second provision (see first page) in this 

Policy confirms the Agency's intention to maximize the use of shared information systems, tools 

and data sets. This should be more efficient and reduce the need to create new separate 

information systems and data collections. 

EPA believes implementation of this Policy and the larger E-Enteprise initiative will enhance the 

ability of EPA and the states to collaboratively manage the national environmental protection 

system based on more complete and shared information. And this will increase the goveriunent's 

ability to perform evidence-based management so that EPA and the states can design and 

implement the most effective environmental programs. The collaboration among EPA, the 

States, tribes and territories on the National Environmental Exchange Network provides many of 

the fundamental building blocks for moving toE-Reporting. 

EPA recognizes that States, local governments, tribes, and territories with authorized or 

delegated environmental programs are key players in the transition to E-Reporting. EPA also 

recognizes that, in some instances, an applicable statute or existing regulation at the federal, 

State, local government or tribal level may need to be amended to allow forE-Reporting. 

However, nothing in this Policy is intended to change the federal and State roles in 

environmental programs, and EPA will work with States, local governments, territories and 

tribes as the Agency includes E-Reporting in new regulations and modifies existing regulations 

to convert from paper toE-Reporting. 

As described in this Policy, E-Reporting is not simply a regulated entity e-mailing an electronic 

copy of a document (e.g., a PDF file) to the government. Rather, E-Reporting is defined as a 

system in which an electronic tool guides the regulated entity through the reporting process often 

with built-in compliance assistance and data quality checks. 

This Policy applies to regulations that will be directly implemented by EPA and regulations that 

will be implemented by authorized or delegated state, tribal or local government programs. For 

existing regulations, the Agency will continue and increase its efforts to convert paper reporting 

toE-Reporting. The details on how to do this expeditiously and efficiently, with appropriate 

business process reviews and streamlining to reduce burden, will be addressed as part of the EEnterprise initiative. 

This Policy does not identify the specific data to be collected thru electronic reporting in a 

particular regulation. And this Policy does not address whether approaches other than reporting 

to the government, such as regulated entities providing certified information directly to the 

public via their own websites, might be appropriate for a particular regulation. Instead, the 

specific data needs and reporting approaches will be addressed as each regulation is developed. 

Bob Perciasepe, US EPA Deputy Administrator