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Appendix D: Burden Reduction Efforts in the UIC Program

In 2006, EPA’s Underground Injection Control (UIC) Program completed an in-depth 

evaluation of options to reduce reporting burden on injection well owners and operators. 

Electronic reporting was identified as the option most likely to offer significant burden 

reduction opportunities for owners or operators and state primacy agencies. 

To increase the use of electronic reporting in the UIC Program, EPA began a number of 

initiatives related to reporting by injection well owners or operators and by permitting 

authorities. This includes developing Agency data systems, supporting state efforts to 

implement electronic reporting by owners or operators, and providing technical and 

financial support to encourage electronic data reporting via the National UIC Database.

This appendix describes these efforts.

Summary of the 2008 Burden Reduction Report

In 2008, the UIC Program discussed the ongoing efforts to reduce reporting burden on 

injection well owners and operators in the paper, “Evaluation of Burden Reduction 

Opportunities Related to Some UIC Program Operator Reporting Forms.” The program 

evaluated the reporting forms that operators are required to submit to determine whether 

opportunities exist to reduce burden. EPA undertook the following activities:

 Created an ad hoc workgroup of regional and state staff to review the necessity of the 

data collected on several of the forms, including forms 7520-6 through 7520-12, 

7520-14, 7520-15, and 7520-16.1

 Reviewed each element on the owner or operator reporting forms to determine 

whether any elements on the reporting forms could be combined or eliminated while 

still ensuring the protection of underground sources of drinking water (USDWs). 

 Explored options for electronic reporting of data, including web interfaces to replace 

the paper forms currently submitted by well owners and operators. 

 Investigated whether any of the needed information could be obtained from other 

sources, e.g., the U.S. Bureau of Land Management (BLM). It was determined that 

BLM forms could not replace any of the UIC Program’s owner or operator 7520 

forms and provide the level of detail needed to meet UIC Program goals.

 

1 These forms include: Permit Application (7520-6), Application to Transfer Permit (7520-7); Injection 

Well Monitoring Report (7520-8); Completion Form for Injection Wells (7520-9); Completion Report for 

Brine Disposal, Hydrocarbon Storage, or Enhanced Recovery (7520-10); Annual Disposal/Injection Well 

Monitoring Report (7520-11); Well Rework Record (7520-12); Plugging and Abandonment Plan (7520-

14); Inventory of Injection Wells (7520-16); and Pre-Closure Notification Form (7520-17).
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Based on the research conducted for the paper, EPA concluded that eliminating forms or 

reducing reporting frequency was not an option due to the following:

 Most of the reported information is required by regulation and is necessary to ensure 

that injection wells will be sited, constructed, and operated in a manner that protects 

USDWs.

 Reducing reporting frequency could endanger USDWs by eliminating crucial early 

warnings that wells are not operating within protective parameters. 

 Combining or eliminating any of the UIC reporting forms is not practical since the 

forms collect information generated at various milestones in the life of an injection 

well or are already submitted infrequently. 

Electronic reporting was identified as an option that might offer significant burden 

reduction opportunities.

Ongoing Burden Reduction Efforts: Owner or Operator Reporting

EPA supports electronic reporting by injection well owners or operators by developing 

Primacy Agency databases and encouraging states to develop their own data systems.

EPA Initiatives 

The Federal Requirements Under the Underground Injection Control (UIC) Program for 

Carbon Dioxide (CO2) Geologic Sequestration (GS) Wells (GS Rule) requires electronic 

submission of all data related to Class VI (GS) wells. The GS Rule requires permit 

applications and all reports, submittals, and notifications required by the rule to be 

submitted electronically. (The rule allows for alternative methods for submission if 

necessary.) EPA took the opportunity to require electronic reporting from owners or 

operators for Class VI wells because the facilities that contain Class VI wells currently 

employ technologies that easily support electronic reporting. The relatively small 

universe of Class VI wells also makes requiring electronic reporting practical. EPA is 

developing a data system to collect and store Class VI well owner or operator data.

State Initiatives 

EPA has encouraged states to create electronic data flows from owners or operators as 

part of the National UIC Database effort, and has encouraged state primacy programs to 

apply for Exchange Network Grants to establish an electronic data flows from owners or 

operators to states. Some programs are taking advantage of the incentive offered by EPA 

to begin electronic reporting for owners or operators while other programs have taken 

their own initiative to reduce reporting burden on owners or operators through electronic 

reporting. For example:

 The Massachusetts Department of Environmental Quality, a 2007 Exchange 

Network Grantee, is beta testing a system for the electronic permitting of Class V 
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wells. The system will include electronic versions of the following forms:

registration and pre-closure, well modification or conversion, well closure, well 

monitoring report, well completion and construction notifications, and well postclosure notification. Access to the system will be controlled with a username and 

password.

 The Wyoming Department of Environmental Quality used a 2005 Exchange 

Network Grant to establish a data flow to EPA, to enhance their UIC database and 

to create the Graduated Environmental Management (GEM) tool. The GEM tool 

allows registered users to apply for a new permit, modify an existing permit, 

manually enter or upload monitoring data, and upload electronic data deliverables. 

GEM collects information related to permits, financial assurance, well construction, 

facility inspections, monitoring, violation, and lab analyses. The tool allows 

reviewers to track the steps in the permitting process, including the method and 

dates of public notice, and whether public comments were received.

 The Washington Department of Ecology employs the Online UIC Well Registration 

System for owners or operators to register their injection wells. The system, 

SecureAccess Washington, is a single sign-on application gateway created to 

simplify access to the Washington’s government services accessible via the 

Internet.

 The State of Utah supports electronic permitting and monitoring reporting for well 

owners or operators. Utah employs eReport, a secure system that uses an Extensible 

Markup Language (XML) data schema to transfer data over the Internet. The 

system allows for submission through:

o Web forms for small operators with a few wells,

o eReportRemote for small and mid-size operators using a spreadsheet-style 

format, and

o Batch submittal for large operators.

Ongoing Burden Reduction Efforts: Electronic Reporting by Permitting Authorities 

EPA encourages state primacy agencies to electronically report required information to 

the National UIC Database by providing technical and financial assistance to establish 

data flows on the National Environmental Exchange Network.

Financial assistance includes information technology activities such as node 

development, database implementation, and modification; data preparation activities such 

as data entry and data modification; and program activities to obtain legal authority to 

implement data flows on the Exchange Network. Financial assistance has also been used 

to support electronic reporting to Primacy Agencies from well owners or operators.

EPA has provided technical support to states through the development of tools to support 

the transition to electronic reporting. For example, EPA developed a primacy program 
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database template based on the structure of the National UIC database to help map 

program data. EPA also developed a Node Client that states without an Exchange 

Network node can use to submit UIC data to the National UIC Database without making 

the investment in a state Exchange Network node. EPA provides on-going assistance to 

several primacy agencies with data mapping, data submission, and data quality 

assurance/quality control activities.

EPA established Integrated Project Teams to provide peer-to-peer support for programs 

that are either beginning to map their data to the National UIC Database or have an 

established data flow. Additional information about this technical support is presented in 

Appendix B of the UIC Programmatic Information Collection Request. 

EPA is also encouraging the shift to electronic reporting by offering Exchange Network 

Grants to support state’s efforts to establish an electronic data flow from owners or 

operators to states (as described above) and then to EPA. To date, 14 states have initiated 

the data transfer process.

Additionally, in FY 2014, to help reduce reporting burden on states, EPA reduced the 

frequency at which e-reporters must upload information to the National UIC database 

from quarterly to semi-annually. This is estimated to result in a burden savings to states

of 3,600 burden hours annually.

Conclusion

EPA continues efforts to encourage primacy programs to develop end-to-end electronic 

data flows starting with operators and ending with EPA. EPA has made grant money 

available to assist state programs in establishing electronic data flows through the 

Exchange Network Grant. To date, over 20 programs have received assistance through 

the Grant.

The support network established for the National UIC Database has provided 

opportunities for peer-to-peer sharing of success stories and lessons learned for electronic 

data flows from owners or operators. EPA has highlighted the efforts of programs with 

end-to-end electronic data flows at national meetings such as the Ground Water 

Protection Council’s annual UIC Conference. 

Without mandating a change in reporting formats, EPA has worked to support the 

implementation of voluntary changes in reporting by owners or operators. Primacy 

programs have also seen the advantages of electronic reporting and have unilaterally

made changes in their reporting practices.