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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

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, 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 
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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 website1; 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.

 

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See:http://www2.epa.gov/compliance/proposed-national-pollutant-discharge-elimination-system-npdeselectronic-reporting-rule
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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
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Date Outreach Activity

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