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Ohio EPA eDMR System Case Study Page 1 

# Case Study: Ohio Environmental Protection Agency’s Electronic Discharge Monitoring Report (eDMR) System Reaches 99% Adoption

Introduction This Case Study highlights how the Ohio E PA launched its eDMR system , which uses electronic reporting to allow perm ittee s to report their discharge measurements quickly and easily online

. This method of reporting, currently at a 99.9% adoption rate, has increased data quality and improved environmental protection, while also saving significant time and resources for a ll stakeholders. Through interviews and data collection, this case study covers the background, challenges, implementation and impacts that the eDMR system adoption had on both permittee s and the state of Ohio. 

### Background

The Clean Water Act of 1972 dele gated to authorized states the authority to regulate surface water within their borders by maintaining a permit program. Any regulated entity discharg ing pollutants into surface water owned by the state is required to have a National Pollutant Discharge El imination System (NPDES) permit. NPDES permits allow state s to control the quantity of pollutants being discharged into their waters , and require permittee s to monitor and report their discharges. This process is intended to ensure compliance with state an d federal regulations that protect public health and the environment.
Since 1972, the US EPA has required the collection of water discharge monitoring data mainly through paper forms. Filling out these forms was labor intensive, requiring permittee s to fi ll them in manually and submit them to either the state or federal agency. The state or the US EPA then manually scanned and verified the data. This process led to some data loss, making it difficult for states and the US EPA to monitor, enforce, and track the progress of clean surface water initiatives in the US. Ohio EPA decided to collect its water discharge monitoring data electronically, eliminating paper forms. In 2005

- 2006 , the Ohio EPA collected 70% of its water discharge information through a soft ware program called SwimWare. The remaining 30% of their data was still collected through traditional paper forms. Unfortunately, both methods were labor intensive for permittee an d the Ohio EPA. The SwimWare program required downloading, installation, and extensive technical knowledge. Data could not be easily updated for errors or for altered permit conditions. Meanwhile, paper forms were often illegible and data were often omitted. Therefore, both methods of data collection resulted in lower data quality

. 

### Challenge

Given their experience with SwimWare and permittee s , the Ohio EPA sought a new data collection system that would allow permittee s to input discharge amounts easily through an online application. The intent was to reduce the labor associated wi th processing the information and increase data quality. Early in the development process of its eDMR system, the Ohio EPA recognized several challenges including outreach, buy

- in, and training. 

### Ohio Implementation

The Ohio EPA faced major challenges inclu ding raising permittee awareness and creating the desire and ability to learn and use a new eDMR system . T o address these challenges, the Ohio EPA took a phased approach to roll out eDMR

.
The Ohio EPA also included various methods to communicate the ben efits of the eDMR system and to train permittee s on the new system.
This approach appears to have led directly to the successful implementation and adoption of the Ohio eDMR system. 

### Nationally, it is reported that 11% of US EPA data analysis is solely dedicated to water disch arge collection

— the largest of any environmental program.

### Ohio EPA eDMR System Case Study Page 2 Roll Out
The Ohio EPA focused on meeting the US EPA’s technical requirem ents , including the Cross

- Media Electronic Reporting Regulation (CROMERR) compliance , prior to roll out. CROMERR provides the legal framework for electronic signature verification and establishes standards for information systems that receive reports and o ther documents electronically

.
The Ohio EPA also piloted early versions of t he system with permittee s that were SwimWare power

- users in order to document their responses, incorporate their feedback , and refine the system in later versions . By focusing on meeting these requirements and engaging permittee s from the beginning, Ohio EPA was able to develop a system that met long

- term agency and permit t ee needs.
Next, the Ohio EPA focused on rolling out the eDMR system to each of the five Ohio EPA districts. E ach month, the Ohio EPA invite d each district, one by one, to use the new system. This allowed them to concentrate their communications and training on a smaller, individualized audience. Working with
s maller groups allowed the Ohio EPA to address the uniq ue needs of each district and create individualized training workshops, which further facilitated adoption. As Figure 1 indicates, the Ohio EPA was able to increase the number of eDMR
users each month.

Figure 1 : Ohio eDMR system Adoption by Month

Ohio EPA also designated a point of contact , or “relationship manager, ” for each district

. The relationship managers became the primary
source s of information for permittee s needing assistance with the new system. The relationship managers were vital for increasing the number of permittee s successfully using the system.

Communications

The Ohio EPA realized that permittee s who were unaware of the new system
, or only ha d a limited understanding of its value , would b e less likely to adopt it . So t he Ohio EPA conducted a permit holder analysis to mitigate this risk. They found that a majority of permittee s preferred phone calls and e

- mail communications.
They also found that these permittee s were not interested in com plex videos or the latest technologies. These permittee s were satisfied with simple and easy to understand communications that were timely and instructive. The communications focused on spreading awareness of the new system and its benefits so permittee s
w ould want to learn more. Ohio EPA also reached out to external governance groups and industry

. They distributed f lyers and brochures to water affiliates including the Ohio Water Environment Association to broaden their out reach.

Ohio EPA focused on the re maining 800 “paper form” permittee s

. Each year , they sent out new blank discharge monitoring forms to those permittee s along with an attached flyer recommending that they use the eDMR system and eventually transitioned them to a request only procedure. Th e Ohio EPA made personal phone calls to the paper form permittee s to individually encourage them to use the eDMR system. Many permittee s quickly transitioned because the focus on personal contact remained central to the Ohio EPA’s approach

. Training
Many permittee s cite the difficulty of learning new systems as an impediment to frequent and correct usage. The Ohio EPA s upported the need for robust training to draw permittee s into the new system. Efficient and diverse training opportunities and information dissemination eased permittee s into the new system and reduced the time needed to engage interest.

### Ohio EPA eDMR System Case Study Page 3 First , Ohio EPA c reated an online “All in One” training document that had screenshots and descriptions of the entire reporting process

. Continuing their fo cus on personal attention, the Ohio EPA also held in

- person training at the various district s each month. They filled over 100 seats at each training event.

The Ohio EPA was aware that Operators, who often prepare reports for permittee s , were required by the state to complete a certain amount of training/coursework each year. The Ohio EPA leveraged this requirement to gain approval for their free three

- hour eDMR system training workshop to fulfill certification requirements to maintain an Operator’s licens e.

The Ohio EPA started each training session with an hour and a half PowerPoint presentation followed by a live demonstration of the system with a permit holder or Operator from the audience . The “permit holder” would create his/her account on the spot to exhibit the system’s ease of use. Eventually, positive word of mouth about Ohio EPA’s eDMR system and the ease of submitting discharge monitoring reports electronically led to more invitations to conduct workshops at regional conferences and other events.


### Result /Outcome

Th e Ohio EPA made significant strides in increasing the number of electronical ly reporting permittee s , decreas ed the amount of time spent manag ing the program , and improv ed data quality to ensure compliance . Ohio’s successful implementation of its eDMR system was due in part to a well

- planned and executed roll out strategy that included diverse communication and training. Over 99% of Ohio permittees no w use the eDMR system (Figure 2).

Figure 2 : Ohio Permittees using eDMR system

Prior to eDMR, Ohio EPA needed five full time staff members to support the DMR program. During eDMR roll

- out they reduced support to two staff members . They now run the program without any full

- time staff. The automa ted compliance tools within the eDMR system inform permittee s if their discharge s exceed their authorized permit limits or if there are data errors . Most of the data errors are user errors and with the new system permittee s
can go back quickly to correct t he errors

. As a result, e rrors have dropped from 50,000 per month to 5,000 per month , giv ing the Ohio EPA more accurate and robust data , which translates into improved data quality. W ith improved data quality, Ohio EPA i s able to better target areas of po l lution , which further improve s Ohio ’s enforcement and compliance program.



### Conclusion

The Ohio EPA created a n eDMR system that saves time and resources for the state and permit holders while dramatically improving data quality. The implementation of the eDMR system has improved the ability of Ohio EPA to monitor and enforce compliance with the Clean Water Act.
Higher data quality and operational efficiency facilitates the agency’s mission to protect human health and the environment. “I used to dedicate over 40 hours a week to this program answering hundreds of e

- mails and phone calls by permit holders. After the deployment of Ohio eDMR system, I’ve been able to reduce my level of effort 75 percent to just 10 hours a week.”

– Ohio EPA Employee

### Ohio EPA eDMR System Case Study Page 4 

### Key Lessons L earned

Ohio EPA eDMR S ystem Team and EPA NetDMRs Contacts:

Name Role E

- Mail Chris Bowman Ohio EPA Information Resource Management ( IRM ) M anager for Division of Surface W ater (DSW) Chris.Bowman@epa.state.oh.us

Randy Crowell Ohio EPA Data Admin istration Manager DSW Randy.Crowell@epa.state.oh.us

Jamie Robert s Ohio EPA eDMR Administrator DSW James.Roberts@epa.state.oh.us Adele Vogelgesang Ohio EPA Information Technology (IT) Manager , IT Services Adele.Vogelgesang@epa.state.oh.us

Catherine Bius US EPA NetDMR Training Lead Bius.Catherine@ epa.gov Nasrine Lescure US EPA NetDMR Technical Lead Lescure.Nasrin@ epa.gov Allison Donohue US EPA NetDMR Communication and Outreach Coordinator Donohue.Allison@ epa.gov



### Additional Information/Resources

Ohio E PA eDMR system Information Page: http://www.epa.ohio.gov/dsw/edmr/eDMR.aspx

Ohio EPA eDMR system Training Guide: http://www.epa.ohio.go v/dsw/edmr/eDMRtraining.aspx

Ohio EPA Link to Answer Place: http://ohioepa.custhelp.com/cgi

bin/ohioepa.cfg/php/enduser/std_alp.php?p_sid=_NxrDJ

- j Roll Out

**•** Ensure CROMERR

- compliance, and engage permittees from the beginning to develop your system

**•** Segment the roll out of an eDMR system to allow for customized communication and tra ining

**•** P rovide a relationship manager to alleviate anxiety and address pressing questions and concerns
Communications

**•** Understand your stakeholders and their communication preferences

**•** Consider using time intensive tactics such as phone calls to win over res istors

**•** Develop partnerships with association s and other like

- minded organizations in your state to broaden your outreach Training

**•** Receive accreditation for eDMR system training to provide an incentive for attendance

**•** Build out Help resources for the eDMR s ystem and use forum boards or e

- mail to answer questions quickly

**•** Offer training both in person and virtually to increase speed of adoption