NPDES Electronic Reporting Rule:

Overview of Appendix A

Region 5 Exchange Network Conference

U.S. EPA Region 5, Chicago, Illinois 

16 April 2015
Overview of Appendix A

• Appendix A is the minimum set of NPDES program data that must be electronically 

collected and shared between NPDES-regulated facilities, authorized NPDES 

programs, and EPA. It is an appendix to the proposed Part 127.

o Authorized NPDES programs may grant electronic reporting waivers to NPDESregulated facilities. In these cases, states perform the data entry from the paper 

submissions.

• Authorized programs that are the ‘Initial Recipient’ of these data must electronically 

transfer these data to EPA on a regular schedule (within 30 days of completed action). 

• EPA/OECA worked with NPDES program experts from the Office of Water, Office of 

General Counsel, EPA Regions, and states to develop and refine Appendix A.

• The purpose of Appendix A is to ensure that there is consistent and complete reporting 

nationwide, and to expedite the collection and processing of the data, thereby reducing 

burden and making the data more timely, accurate, complete, useful, and transparent 

for everyone.

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EPA Region 9 Annual 

Pretreatment Reports

EPA Region 7 Annual 

Biosolids Reports

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NPDES Programs Need Standardized Electronic Data to 

Reduce the Burden of the Existing Paper Reporting System 
Overview of Appendix A

• When reviewing the list of Appendix A data elements it is important to note several 

concepts:

o Frequency: Reporting frequency varies based on the type of data (e.g., permit issuance 

would likely be every five years; DMR data may be monthly).

o Applicability: Many of the data elements are only applicable to certain NPDES sectors (e.g., 

CAFO data wouldn’t apply to POTWs).

o Utility: Many of the data elements use codes or unique descriptions to facilitate easier 

analysis and reporting. This will allow state and EPA Regions to more efficiently identify noncompliance and water quality issues.

• EPA’s Headquarters and Regional permitting program and enforcement staff used 

the following process to create the initial draft of Appendix A:

o Identify current candidate reports and information from states and NPDES regulated entities 

that are practical to standardize and electronically process, and have important value to the 

permitting, compliance and enforcement program, and the public.

o Identify the required data elements for each candidate data flow and report based on the 

CWA or existing EPA regulations or policy. 

o Minimize the number of data elements to create efficiencies without losing the utility of the 

data. 

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Here’s an example....

• Stormwater discharges, including discharges from municipal separate storm sewers 

(MS4s), industrial facilities and construction sites, can have a significant impact on 

water quality. EPA has identified this as a area of focus for the NPDES program.

• In 1990 (Phase 1) and 1999 (Phase II) EPA created reporting requirements for MS4s:

• Annual for Phase I MS4s (Large and Medium); and

• Year 2 and 4 of the permit term for Phase II MS4s (Small). 

• These long-standing regulations require MS4s to summarize their enforcement 

activities (along with other data):

o Phase 1 [122.42(c)(6)]: “A summary describing the number and nature of 

enforcement actions, inspections, and public education programs.”

o Phase II [122.34(g)(3)(i)]: “The status of compliance with permit conditions, an 

assessment of the appropriateness of your identified best management 

practices and progress towards achieving your identified measurable goals for 

each of the minimum control measures” [emphasis added]

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Here’s an example....

• EPA used this regulatory language to develop the following data elements to 

capture the inspection and enforcement actions taken by the MS4 program 

report.

o MS4 Enforcement Action Type

o MS4 Enforcement Action Number

o MS4 Municipality Enforcement Agency

• These data (and other data from the MS4 program report) will help states, 

EPA, and the public better understand the performance of each MS4 

program. This is lacking in the current paper-based system.

o Some states have noted that they currently rely on reviewing 200 page 

reports from MS4 to evaluate permit compliance.

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Color Code for Appendix A to 

40 CFR 127

(Required NPDES Data Elements)

Yellow — For these data elements, regulated facilities will be the sole 

or predominant source of the electronic data;

Pink — For these data elements, states and EPA will be the sole or 

predominant source of the electronic data.

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Overview of Appendix A

• Appendix A is divided into 36 sections and seven larger 

groupings.

– These seven groupings are: basic facility data, universal permit/NOI 

data; subprogram permit/NOI data; inspection data; DMR data; 

program report data; and violation and enforcement action data.

• There is a direct relationship between the amount of data that will 

be reported, collected, and managed and the overall burden of 

the rulemaking. Consequently, it is important to focus on the 

amount of data that will be collected and not the number of data 

elements. 

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Inspection Data

DMR Data (11 data 

elements, frequency

varies with permit 

requirements, may be 

monthly)

29 data elements, 

as inspections 

occur

Program Report Data

112 data elements, 

usually annually

Appendix A Seven Data Groupings: 

Amount of Information and Number of Data Elements

28 data elements, 

as situations occur

Basic Facility Data

29 data elements, 

once every 5 years

120 data elements, 

once every 5 years

88 data elements, 

once every 5 years

Subprogram Permit/NOI 

Data

Universal Permit/NOI Data 

(including effluent limits 

and outfalls)

Violation and Enforcement Action Data

Yellow — for these data elements, 

regulated facilities will be the sole or 

predominant source of the data;

Pink — for these data elements, 

states and EPA will be the sole or 

predominant source of the data.

Note: The height of these boxes are intended to 

reflect the relative, but not exact, amount of 

information required for each data grouping.

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Data Uses ->

Identify regulated universe, applicable 

requirements, and environmental significance

Determine and Document 

Compliance Status

Document Enforcement Activities and 

Responses to Non-Compliance
NPDES Information Sought under This Rule

1. Basic Facility Data

Inspection Data

DMR Data

Program Report Data

Subprogram Permit/NOI 

Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls)

Violations and Enforcement Action Data

Key Points

1) 29 data elements

2) Primarily address and contact information

3) Most likely source: electronic NOIs and 

paper individual permit applications 

4) Frequency: once every five years, usually 

upon permit reissuance

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NPDES Information Sought under This Rule

Inspection Data

DMR Data

Program Report Data

Subprogram Permit/NOI 

Data Violation and Enforcement Action Data Basic Facility Data

2. Universal Permit/NOI 

Data (including effluent 

limits and outfalls)

Key Points

1) 88 data elements

2) 38 for basic permit information, 6 for 

narrative conditions and permit schedules, 

12 for permitted features, 9 for limit sets, 

and 23 for limits

3) Most likely source: authorized NPDES 

programs

4) Frequency: once every five years, usually 

upon permit reissuance

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NPDES Information Sought under This Rule

3. Subprogram Permit/NOI 

Data

Inspection Data

DMR Data

Program Report Data Violation and Enforcement Action Data Basic Facility Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls)

Key Points

1) 120 data elements total

2) 8 for biosolids, 15 for AFO/CAFOs, 16 for 

industrial and construction stormwater, 26 

for MS4s, 18 POTW specific, 14 for 

pretreatment programs, 15 for cooling water 

intake structures, and 8 for thermal 

variances

3) Most likely source: electronic NOIs and 

paper individual permit applications

4) Frequency: once every five years, usually 

upon permit reissuance

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NPDES Information Sought under This Rule

Subprogram Permit/NOI Data

DMR Data

Program Report Data Violation and Enforcement Action Data Basic Facility Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls)

Key 4. Inspection Data Points

1) 29 data elements total

2) 13 universal data elements for any 

inspection, 1 for biosolids inspections, 7 

for AFO/CAFO inspections, 7 additional 

for sewer overflow inspections and 

audits, and 1 for pretreatment 

inspections and audits

3) Most likely source: inspection reports 

from authorized NPDES programs

4) Frequency: varies based on facility type

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NPDES Information Sought Under This Rule

Subprogram Permit/NOI 

Data Program Report Data Violation and Enforcement Action Data Basic Facility Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls) 

Inspection Data

5. DMR Data

Key Points

1) 11 data elements 

2) Self-monitoring data

3) Largest data entry 

burden due to multiple 

outfalls, pollutants, and 

measurements

4) Frequency: varies with 

permit requirements, 

usually monthly for major 

facilities

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NPDES Information Sought under This Rule

Subprogram Permit/NOI 

Data Violation and Enforcement Action Data Basic Facility Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls)

Inspection Data

DMR Data

6. Program Report Data

Key Points

1) 112 data elements total

2) Self-monitoring data (mostly reported on 

paper forms today)

3) 4 for all program reports, 14 for biosolids 

annual reports, 34 for CAFO annual 

reports, 13 for MS4 program reports, 29 

for pretreatment annual reports, 12 for 

sewer overflow or bypass reports, and 6 

for CWA §316(b) Annual Report

4) Frequency: mostly annual except for 

sewer overflow event report and small 

MS4s (twice per permit term)

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NPDES Information Sought under This Rule

Subprogram Permit/NOI 

Data

Basic Facility Data

Universal Permit/NOI Data 

(including effluent limits and 

outfalls)

Inspection Data

DMR Data

Program Report Data 7. Violation and Enforcement Action Data

Key Points

1) 28 data elements total 

2) 2 common data elements, 8 

for violations, 7 for 

enforcement actions, 2 for 

final orders, 2 for penalties, 

and 7 for compliance 

schedules

3) Data from authorized 

NPDES programs

4) Frequency: Within 30-days 

of completed action

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Current Status of Appendix A

• EPA is currently working with states to review each data element prior to EPA 

internal review of the final rule (May 2015). 

o This review started in January 2015 and took approximately ten 90-minute 

meetings.

o EPA also conducted a similar in-depth review of Appendix A in 2014 to 

support the publication of the Supplemental Notice (1 December 2014).

• EPA/OECA is also working with OWM and Regional subject matter experts to 

refine Appendix A.

• Finally, EPA/OECA is also reviewing options for staggering implementation of 

the new state supplied data elements (e.g., subprogram data elements that are 

provided during permit issuance or renewal).

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