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### MEMORA**NDUM** 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@ e pa.gov DATE: 26 November 2014 SUBJECT: Outreach for the Proposed NPDES Electronic Reporting Rule [DCN 0111] **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, avail able 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 co mpliance 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 accoun tability 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 h eld over 30 webinars and meetings with over 1,200 peop le 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 Decembe r 2013 to form a State Technical Workgroup to discuss issues related to the eRule . Th is 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 conduct2

additional stakeholders meetings to further discuss and refi ne particular aspects of the rule prior to promulgation. Outreach to stakeholders will continue to be supported through the NPDES Electronic Reporting Rule website 1; however, the website may be expanded to include more robust rule schedules as the rule nea rs promulgation, as well as additional rule documentation that may or may not be included as part of the formal docket library.

1See:http://www2.epa.gov/compliance/proposed

- national
- pollutant
- discharge
-elimination
-system - npdes
electronic
- reporting
- rule3

**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 (Si erra 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) Septembe r 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: F undamentals of Building

and Maintaining a Pretreatment Program April 10, 2014 Presentation at R egion 3 Pretreatment Conference4 **Date Outreach Activity**  June 11, 2014 Associated General Contractors of America (AGC) August 4, 2014 ACWA Summer Meeting August 5 - 6, 2014 Presentation at R egion 6 Pretreatment Conference September 22, 2014 N orth Carolina Pretreatment Conference Sept 27 – Oct 1 , 2014 WEFTEC National Meeting – New Orleans Oct 6 – 8, 2014 NRWA Conference – Seattle