# A Business Case Analysis of EPA’s Central Data Exchange

March, 2007CDX Business Case Analysis

March, 2007 i 

## ACKNOWLEDGEMENTS

The Office of Environmental Information recognizes and thanks everyone who contributed to the CDX business case analysis.

Paul Borst, EPA Jeff Brown, Environmental Health Labs Jeff Bryan, EPA Chris Clark, EPA Dave Clayton, CCS Technologies John Cooper, EPA Connie Dwyer, EPA Don Egan, LMI Chris Freebis, EPA Chuck Freeman, EPA George Hallberg, CADMUS Michael Hart, EPA Roger Howard, EPA Susan Hunt, CSC Chuck Job, EPA Kristine Karlson, EPA Brent Larson, EPA John Lavery, CSC Ed Lillis, EPA Nick Mangus, EPA Chris Matthews, CSC Greg Mitchell, EPA Abe Siegel, EPA Julie Simpson, EPA Nikos Singelis, EPA Tony Sledge, CSC Everett Spencer, EPA Wendy Timm, EPA Deborah Venci, Barium & Chemicals, Inc Bryan Weiner, Toll Brothers, MA Larry Weiner, EPA (retired) Josh Woodyard, EPA Robert Wright, EPA

CDX Business Case Analysis Project Team Mary Greene, EPA Jeffrey Wells, EPA Vernon Fernandes, CSC Norm Duncan, CSC Deborah Miller, CSC Phill Thomas, Innovate! Tori Adams, Innovate!

This report was prepared under EPA Contract Nu mber GS00T99ALD0203, Task Order number T038.CDX Business Case Analysis

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# Table of Contents

1. EXECUTIVE SUMMARY.............................................................................................................. ... 1

2. INTRODUCTION................................................................................................................... ............ 1

2.1 B ACKGROUND .............................................................................................................................. 3 2.2 P URPOSE AND S COPE .................................................................................................................... 4 2.3 A SSUMPTIONS AND L IMITATIONS ................................................................................................. 5 2.4 S ELECTION OF D ATA F LOWS ........................................................................................................ 6

3. APPROACH....................................................................................................................... ................. 8

4. SDWIS BENEFIT ASSESSMENT.................................................................................................. 13

4.1 P ROGRAM D ESCRIPTION ............................................................................................................. 13 4.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 13 4.3 O PERATIONAL B ENEFITS OF SDWIS U SE OF CDX .................................................................... 15 4.3.1 Timeliness..................................................................................................................... ........ 16 4.3.2 Data Qu ality ................................................................................................................... ...... 16 4.3.3 Accessi bility.................................................................................................................. ........ 16 4.4 M ONETARY B ENEFITS OF SDWIS U SE OF CDX......................................................................... 16

5. LEAD-BASED PAINT ABATEMENT PROGRAM BENEFIT ASSESSMENT ....................... 18

5.1 P ROGRAM D ESCRIPTION ............................................................................................................. 18 5.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 18 5.3 O PERATIONAL B ENEFITS OF L EAD

- BASED P AINT A BATEMENT P ROGRAM U SE OF CDX............ 20 5.3.1 Timeliness..................................................................................................................... ........ 20 5.3.2 Data Qu ality ................................................................................................................... ...... 21 5.3.3 Accessi bility.................................................................................................................. ........ 21 5.3.4 Ancillary Benefit.............................................................................................................. ..... 21 5.4 M ONETARY B ENEFITS OF L EAD

- BASED P AINT A BATEMENT P ROGRAM U SE OF CDX................ 21

6. UCMR BENEFIT ASSESSMENT .................................................................................................. 23

6.1 P ROGRAM D ESCRIPTION ............................................................................................................. 24 6.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 24 6.3 O PERATIONAL B ENEFITS OF UCMR U SE OF CDX ..................................................................... 26 6.3.1 Timeliness..................................................................................................................... ........ 26 6.3.2 Data Qu ality ................................................................................................................... ...... 27 6.3.3 Accessi bility.................................................................................................................. ........ 27 6.3.4 Ancillary Benefit.............................................................................................................. ..... 27 6.4 M ONETARY B ENEFITS OF UCMR U SE OF CDX ......................................................................... 27

7. TRI BENEFIT A SSESSMENT........................................................................................................ 3 0

7.1 P ROGRAM D ESCRIPTION ............................................................................................................. 30 7.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 30 7.3 O PERATIONAL B ENEFITS OF TRI U SE OF CDX .......................................................................... 32 7.3.1 Timeliness..................................................................................................................... ........ 33 7.3.2 Data Qu ality ................................................................................................................... ...... 33 7.3.3 Accessi bility.................................................................................................................. ........ 33 7.3.4 Ancillary Benefits ............................................................................................................. .... 33 7.4 M ONETARY BENEFITS OF TRI U SE OF CDX ............................................................................... 34CDX Business Case Analysis

March, 2007 iii 8. E-NOI BENEFIT ASSESSMENT ................................................................................................... 37

8.1 P ROGRAM D ESCRIPTION ............................................................................................................. 37 8.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 37 8.3 O PERATIONAL B ENEFITS OF E -NOI U SE OF CDX ...................................................................... 38 8.3.1 Timeliness..................................................................................................................... ........ 39 8.3.2 Data Qu ality ................................................................................................................... ...... 39 8.3.3 Accessi bility.................................................................................................................. ........ 39 8.3.4 Ancillary Benefits ............................................................................................................. .... 39 8.4 M ONETARY B ENEFITS OF E -NOI U SE OF CDX........................................................................... 40

9. AQS BENEFIT ASSESSMENT ...................................................................................................... 42
9.1 P ROGRAM D ESCRIPTION ............................................................................................................. 42 9.2 P RE -CDX AND P OST -CDX P ROCESSES ...................................................................................... 42 9.3 O PERATIONAL B ENEFITS OF U SING CDX IN AQS...................................................................... 42 9.4 M ONETARY B ENEFITS OF U SING CDX IN AQS.......................................................................... 43

10. SUMMARY OF FINDINGS ....................................................................................................... 44

10.1 F INDINGS ON M ONETARY B ENEFITS .......................................................................................... 44 10.2 F INDINGS ON O PERATIONAL B ENEFITS ...................................................................................... 46CDX Business Case Analysis

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# 1. EXECUTIVE SUMMARY

In 2000, EPA’s Office of Environmental Informati on (OEI) began building the Central Data Exchange (CDX) with a vision toward enabling the Agency and its partners to exchange environmental data more easily over the Internet. OEI personnel believed that they could build a system that improved EPA data quality, timeliness, security, and accessibility while enabli ng the Agency as a whole to garner efficiencies by consolidating data exchange activities around a robus t data exchange architecture. Today, CDX is well on its way to achieving that vision. It is EPA’s connection or “Node” on the Environmental Information Exchange Network to share data with states and tribes and it incorporates data exchange activities for over 30 EPA programs. CDX began production with the National Emissions I nventory in 2001. In 2004, OEI launched this business case analysis to assess the impact of CDX on six programs using CDX to exchange their data. These programs reside in four EPA Program Offices and represent a cross section of the Agency. The four Program Offices are: Air and Radiation; Wate r; Prevention, Pesticides and Toxic Substances; and Environmental Information. The six program data exchang es, or data flows, selected for this analysis are: 

### 3⁄4 Safe Drinking Water Information System (SDWIS) 

### 3⁄4 Lead-based Paint Abatement Program 

### 3⁄4 Unregulated Contaminant Monitoring Rule (UCMR) 

### 3⁄4 Toxic Release Inventory (TRI) 

### 3⁄4 Electronic Notice of Intent (e-NOI) 

### 3⁄4 Air Quality System (AQS).
The analysis focused on monetary, operational and othe r benefits these data flows gained by integrating CDX into their business process. We calculated monetary benefits against one of two baseline scenarios: 1) the cost of the data flow process prior to CDX; or 2) the assumption that, because of emerging information security and other requirements, the Pr ogram Office would have needed to develop its own in-house system similar to CDX if they did not use CDX itself. To ensure a conservative and sensible approach to the analysis, OEI and program data flow managers jointly selected th e baseline scenario to be used and collaborated on the overall calculation of th e return on investment (ROI). The ROI and net benefit calculations also assume that in FY 2007, Program Offices would begin to share operations and maintenance (O&M) costs for CDX. 1



### OEI used a structured process in data collection and analysis, including interviews with Program Office personnel to develop process maps for the data flow before and after CDX integration, and to develop estimated costs and benefits from the use of CDX. Where possible, the report identifies any operational and other benefits observed such as improvements in information quality, timeliness and accessibility, but does not monetize them or include them in the overall monetary benefit calculation. Program Office staff collaborated with OEI throughout the study and resu lts were presented to and approved by Program Office management and OEI before this report was pr epared. The results presented offer a snapshot in time of estimated benefits that the six Program O ffice data flows garnered from CDX. Because the benefit assessments were intentionally conservative, curre nt or actual benefits are likely greater than those projected in the estimates.
Summary benefits are captured in the tables on the ne xt page and should underscore the narrow scope of this study, which captures and monetizes only a pa rt of CDX’s impact on Agency business processes while noting other benefits anecdotally along the way. The analysis does not multiply the benefit from these six flows to the remaining Agency programs. It does not attempt to calculate any Agency-wide

1 Now, Program Offices will not begin to pay these expe nses until FY2008 or FY2009 at the earliest. No adjustment was made to the benefit calculation presented in the report to reflect this change in timing.CDX Business Case Analysis

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### benefit that CDX might provide through enhanced da ta security, or by enabling the consolidation of multiple manual and electronic program data coll ection systems across the Agency into one. Nevertheless, this study clearly demonstrates C DX’s positive result to date for EPA.

Monetary and Other Benefits

Program Data Flow Net Monetary Benefit (savings/avoided future cost) Examples of Other Benefits



### SDWIS $765,600 Data review used to require weeks or months of manual effort. With CDX, Primacy Agencies can now detect and respond to errors within minutes or hours


### Lead-based Paint Abatement $9,500,000 Form processing used to require an average of 10 days. Applicants now

apply directly on the Web and use built-in data quality checks and a

direct connection to pay.gov reducing average processing time to 2 days 

### UCMR $91,150 CDX reduced data preparation time from 5-7 years to 90-120 days.


### TRI $1,481,102 CDX reduced error rates from 10.4% for paper processing and 2.1% for diskette processing to 0.6%


### e-NOI $230,152 CDX eliminated approximately 33 days of processing time to obtain a permit.



### ROI Summary

Program Data Flows 

### SDWIS UCMR TRI e-NOI

Estimated Return on Investment 119% 5% 271% 32%



### The variance in monetary and operational benefits among data flows stems from several independent factors including: which components of CDX services are used by the data flow; the nature of the information system prior to adopting CDX; at what point in the system development lifecycle the data flow integrated CDX; the number of data submissi ons handled by CDX; and numerous other factors. Monetary benefits are therefore not strictly compar able across the flows examined. An ROI for AQS was not calculated because there was no monetary benefit projected although the AQS flow anticipated data quality and accessibility benefits through CDX’s conn ection to the Exchange Network. No monetary benefits were found because the AQS system itself had just been modernized and incorporated many of the same electronic features that CDX offered at the ti me. In the case of Lead Abatement, future avoided costs shown are expected to be substantial but an ROI calculation was judged premature given the relatively small number of submissions received to date through CDX and the difficulty in predicting future CDX use by Program applicants.CDX Business Case Analysis

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# 2. INTRODUCTION
2.1 Background

In 2000, EPA’s Office of Environmental Informati on initiated creation of a Central Data Exchange (CDX) mechanism for the Agency and its partners to electronically collect and share environmental reporting and related information. CDX was designed to enable rapid, secure, efficient, and accurate environmental data collection and publication servi ces to EPA and its partners – state and local governments, industry, and tribes. CDX is EPA’s Node on the Environmental Information Exchange Network (Exchange Network) and is the standard for information collection and exchange compliance with EPA’s Enterprise Architecture. The role of CDX as EPA’s Node on the Exchange Network is illustrated in Exhibit 2-1. (Note that Exhibit 2-1 is for illustrative purposes only; it does not include all partners or interrelationships.)
Exhibit 2-1. The Role of CDX as EPA’s Node on the Exchange Network

Web Forms

Help Desk & Operations

Support Hosted & Distributed Integration Services Security Services Data Quality Services 

### Central Data Exchange

eGov Initiative Partners

Pay.gov Grants.gov

E-Authentication

Federation 

### Industry Partners

Water Utilities & Power Plants Chemical Producers

Oil Refineries Automobile Manufacturers 

### EPA Program Office Partners

eIUR

AQS UCMR

EnviroFlash TRI

FRS



### EPA Regional Partners Region 4 - CAFO
Region 5 - GeoExchange 

### Intra-Agency Initiative Partners General Public

Tribal Partners

Eastern Band of Cherokees Wind River 

### Tribal Partners

Eastern Band of Cherokees Wind River 

### State Partners

California Air Resource Board Indiana eMits 

### State Partners

California Air Resource Board Indiana eMits



### Internet

Web Services



### The first program implemented data exchange through C DX in 2001. As of the publication of this report, CDX is accepting data for air, water, waste and toxics programs for 30 individual data flows. CDX exchanges data either from external users directly to program data systems, or posts data received from external users to a secure directory from which an EPA program may access and download. In both instances, the system architecture serves as a secure br idge between EPA’s internal data systems and its data sharing partners. Through CDX, users can:

• Submit environmental data to EPA or other stakeholders using CDX as a centralized access point to distribute the data to all applicable recipients.CDX Business Case Analysis

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### • Retrieve or publish environmental data on a prescheduled or ad-hoc basis with EPA or other stakeholders.

• Validate quality of environmental data through automate d compliance checks with agreed upon data standards and business rule valid ation checks on exchanged data.

CDX is intended to eliminate or reduce risk associ ated with electronic submission of data as outlined below:

• Security – Use of CDX ensures data security during transmission.

• Delivery – Use of CDX ensures secure delivery.

• Technology – CDX offers a proven infrastructure so that users avoid the risks associated with use of untested technology.

• Financial – Use of CDX offers a proven infrastruct ure and economy of scale benefits, thereby reducing the financial risk to EPA Program Offices whose data flows use CDX.
EPA anticipated that implementation of CDX would be nefit stakeholders by streamlining and simplifying data exchange in the following ways:

• Ability to submit data through one centralized point of access for distribution to multiple end users.

• Completion of a single electronic form that can be submitted instantaneously to EPA instead of mailing multiple paper forms.

• Automated confirmation of data receipt sent to the user.

• Submission of data in a variety of formats including Web forms, XML (Extensible Markup Language), binary, or flat file.

• Improved data quality through valid ation checks on submitted data.

• Data exchange between different system platfo rms, languages, and formats using Web services.

• Publishing services to share information collected by EPA with other stakeholders, including states and tribes.

In 2004, EPA’s Office of Environmental Informati on (OEI) initiated a business case analysis to estimate the monetary and operational benefits to several of EPA’s Program Office partners that implemented data exchange through CDX. 

## 2.2 Purpose and Scope

The purpose of this analysis was to assess the imp act of CDX use on representative data flow processes and determine the monetary and oper ational benefits of CDX use to th e Program Offices that manage the data flows. The results of the analysis presented in this report offer a snapshot in time of estimated benefits of CDX use. The analysis occurred from 2004 through 2006 and included six data flows. This report presents the assessment of benefits at the time the particular data flow was examined.

The scope of this analysis was to examine and estimat e the monetary benefits (i.e., cost avoidance) and operational benefits to specific Program Offices who use CDX for their data flows. OEI limited the scope of the analysis for cost efficiency. No state, industr y, or OEI benefits or costs were incorporated; and the analysis did not consider potential benefits to hum an health or the environment that may result from increased data timeliness, quality, and accessibility. Meanwh ile, the Environmental Council of the States (ECOS) recently completed an in-depth analysis of st ate benefits from use of the Exchange Network.CDX Business Case Analysis

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### ECOS’ report, Exchange Network Return on Investment and Business Process Analysis , was published in June 2006 and can be found at http://www.exchangenetwork.net . It contains a customized ROI model that states can use as a tool to estimate the return on investment for data flows that use the Exchange Network.

The CDX business case analysis focused on two aspects of benefits to the Program Offices: 1) monetary benefits resulting from integrating CDX into the data flow process, and 2) operational benefits attributable to data exchange via CDX. The ope rational benefits examined included improvements in timeliness, data quality, and data accessibility. Alth ough improved operational efficiencies result in cost savings, OEI did not assign a monetary value to the op erational benefits because suitable models were not available. The time frame considered in each data flow analysis varied depending on when the system began development and went into production. The typical time frame considered was 7-8 years (2-3 years for development and 5 years for operation).

EPA plans to use the results of this business case an alysis to develop a model that Program offices can use to assess the advantages of adopting CDX, and identify and implement business process improvements that enhance CDX’s value to users. St akeholders are encouraged to use the data presented in this report to consider potential benefits CDX c ould offer in reducing costs and enhancing data quality, timeliness, and accessibility within their data flow processes. 

## 2.3 Assumptions and Limitations

In conducting the analysis, OEI made the assumption th at Program Offices would need to develop their own in-house systems similar to CDX if they did not use CDX. These anticipated costs were considered in the analysis, except where noted in this report. Most Program Offices interviewed were aware of deficiencies in their current data exchange capabilities and were seeking to improve, or had already taken steps to improve, their data exchange through electronic reporting.
A second assumption was that in future years Program Offices would pay O&M costs for their data flows in CDX and a share of the overall CDX infrastructure. OEI currently bears these costs, as well as other costs, but is considering implementing a cost-share ap proach for participating Program Offices. Because the CDX cost share had not been determined at the tim e of the study, an industry standard estimate of 20 percent of the development cost typically was used to derive the O&M estimate. Inclusion of these costs in the analysis ensures that CDX benefits are not overestimated in the event that Program Offices incur these costs during the operational period projected in the analysis.
Availability and level of detail of cost information va ried significantly across data flows. Additionally, some historical information was not available. Th ese variances and the differences in application of CDX in each data flow made it impractical to compare benefits across data flows.
The CDX financial model used in estimating monetary benefits is conservative (i.e., prejudiced toward higher costs) to avoid overestimating benefits. The operational benefits of CDX use cited in this report were clearly valuable to the Program Offices, but th ere were no available models to assign a universally accepted or applicable dollar value to these benefits . Improved operational efficiencies in time saved, improved data handling, reduced probability of errors, standard formatting, ease of accessibility, and rapid data transfer would require a case-specific appro ach to reflect the particular data flow factors. Because operational improvements were not quantifie d in monetary terms, the estimated monetary benefits are conservative. The actual monetary bene fits are likely higher than those reported in most

cases.CDX Business Case Analysis

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## 2.4 Selection of Data Flows

EPA sought to select a representative sampling of Prog ram Office data flows for participation in the business case analysis. Four primary criteria were used for selection: 1) Availability of program resources to work w ith OEI on developing case analysis data, 2) Data flow that involved significant ongoing data volume, 3) Implementation of the data flow through CDX was complete, and 4) Cost data were available.

Based on these criteria, EPA initially chose four data fl ows; two more data flows were added as they met the same criteria. A total of six data flows were examined during the 2004-2006 time period. Exhibit 2-2 lists the data flows selected for the business case anal ysis, identifies the EPA Program Offices responsible for each data flow, provides a brief overview of the da ta flow, and indicates the use of CDX in the data flow.

Exhibit 2-2. Data Flows Examined in EPA’s Business Case Analysis

Data Flow EPA Program Office Data Flow Description Use of CDX

SDWIS (Safe Drinking Water Information System) Office of Ground Water and Drinking Water (OGWDW) All public water suppliers submit compliance and enforcement information to EPA for inclusion in SDWIS, as required by the Safe Drinking Water Act (SDWA) Amendments of 1996. Data are used for the Public Water System Supervision (PWSS) Program. 3⁄4 Used CDX to re-engineer a process from a combination of paper/diskette submission to full electronic reporting.

Lead-based Paint Abatement Office of Pollution Prevention and Toxics (OPPT) A federal training and certification program for leadbased paint abatement activi ties (inspection, risk assessment, and abatement) in target housing and child-occupied facilities in those states, territories, and Indian tribes that are not operating their own EPA-authorized lead training program 3⁄4 Used CDX to re-engineer a paper process and enable electronic reporting, including quality checks during data entry.

UCMR (Unregulated Contaminant Monitoring Rule) OGWDW UCMR was the regulatory mechanism used to describe procedures to report, evaluate, and prioritize contaminants on the Drinking Water Contaminant Candidate List. Data are used to support sound, science-based decisions on drinking water standards. Each 5 years, public water supply locations submit data about unregulated contaminants via CDX to the SDWARS (Safe Drinking Water Accession and Review System) database. 3⁄4 Used CDX to re-engineer a paper process and enable electronic reporting; excluded SDWARS database from scope.

TRI (Toxic Release Inventory) Office of Information Analysis and Access (OIAA) Database that contains information on toxic chemical releases reported by certain covered industry groups and federal facilities. EPA compiles the TRI data each year from approximately 25,000 submitters and makes it available through data access tools, including the TRI Explorer and Envirofacts. Used CDX to re-engineer a paper or diskette process and enable electronic reporting; (the study scope did not include advantages from the use of the TRI-ME software to complete forms).

e-NOI (Electronic Notice of Intent) Office of Wastewater Management (OWM) The Notice of Intent (NOI) is the primary document used by EPA to monitor and enforce industry compliance with the National Pollutant Discharge Elimination System (NPDES) permitting requirements to abate storm water runoff. CDX is used to allow permit applicants (such as construction companies) to electronically submit their NOIs and Notices of Termination (NOTs). 3⁄4 Used CDX to re-engineer a paper process and enable electronic reporting; included the back-end database and all components of e-NOI and CDX in scope.CDX Business Case Analysis

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### Exhibit 2-2. Data Flows Examined in EPA’s Business Case Analysis

Data Flow EPA Program Office Data Flow Description Use of CDX

AQS (Air Quality System) Office of Air Quality and Planning Standards (OAQPS) Repository of ambient air quality data periodically submitted by State, local, and tribal agencies. AQS stores data from more than 10,000 monitors, 5,000 of which are currently active. 3⁄4 Added CDX to an already modernized AQS data collection capability.CDX Business Case Analysis

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# 3. APPROACH

Before initiating the study, EPA developed a structured plan for the data collection and analysis process. EPA’s approach is illustrated in Exhibit 3-1. Th is section describes each of the steps shown in the exhibit. This approach was applied to all six Pr ogram Offices and data flows examined. Data collection and analysis information for individual data flows is presented in Sections 4 through 9.
Exhibit 3-1. Overview of EPA’s Approach to the Business Case Analysis



## Step 1 – Develop template for collecting data

Initially, OEI staff met with personnel from CSC’s proj ect team to develop a standard list of questions that would be used to elicit the information required to conduct the analysis. These template questions are shown in Exhibit 3-2. It was recognized that because of the differences in the data flows, these questions would lead to more specific questions for each data flow. However, the use of these questions ensured basic consistency in the approach to data collection.

Exhibit 3-2. Template Questions Used in Data Collection

GENERAL Which of the following CDX serv ices does your data flow use? Data Submission Data Validation Duplicate Risk Assessments & Documentation
Hardware and Software 

### – Purchases & Maintenance Help Desk / Problem Resolution (Tech. Questions , Triage, extract data from SDWARS and post to public) Notifications/Alerts Reporting Step 1 Develop template for collecting data

Step 2 Conduct interviews with program data

flow managers

Step 3 Develop pre- and post-CDX process maps Step 4 Develop cost

estimates

Step 5 Develop benefit estimates

Step 6 Develop before/after storyboards Step 7 Review/confirm results with program data flow manager

Step 8 Program management

briefings

Step 9 Finalize benefit report summariesCDX Business Case Analysis

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### Exhibit 3-2. Template Questions Used in Data Collection

GENERAL Secure Data Transmission (plus partitioning) System Administration Archiving Content Management Database Management System (DBMS) E-mail Error Handling Identity Management Systems Management Transaction Logging Web Forms Web Server Web Services Toolkit XML Metadata Management DATA QUALITY What did the pre-CDX data collection process look like? What data quality problems have now been resolved and what are the cost savings? How many people or systems now handle a data submission before it reaches you? How many instances of your data do you mainta in? How often do you synchronize your data? Do you have meta-data associated with your data model? Do you now have a rules engine in place? If not, do you need one? Do you now have a pre-populated header? If not, do you need one?
DATA TIMELINESS How do you measure timeliness? Receive data to publish? How long does it now take a data submission to get from the submitter to your system? Which parts of the submission process has CDX automated? How often are data refreshed or sy nchronized amongst key users? How rapidly do you need the data? Where are the bottlenecks in your system? How much in cost savings do you attribute to this automation?
DATA ACCESS How many users could access the data they needed before CDX? How has CDX improved data access for your dataflow? How has improved data access improved service to stakeholders?



## Step 2 – Conduct interviews with program data flow managers

EPA and CSC project team personnel met with data flow managers in the respective programs. In-person meetings were held with local Program Offices; phone calls were used with out of town offices. Followup clarification phone calls were made to all offices. The project team began the analysis for each data flow by meeting with the program data flow manage rs to determine the basic assumptions that would be used in the study, the time period the analysis would cover, what staff would need to be involved, and what data were available. The time frame considered in the analysis was typically 7-8 years (2-3 years development and 5 years operation). Time periods for each data flow varied depending on when the system began development and went into production. The project team generally focused on the periodCDX Business Case Analysis

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### FY2003 through FY2008; however, this time period varied . The duration of the analysis and start and end points were adjusted to fit the particular data flow implementation or data collection cycle. 

## Step 3 – Develop pre-CDX and post-CDX process maps

The project team worked with the program data fl ow managers to develop process maps (i.e., flow diagrams) of the data flow process prior to using C DX and the data flow process after using CDX. From these process maps, the project team identified the cost elements associated with the processes and identified the most likely areas of cost avoidance. 

## Step 4 – Develop cost estimates

Cost estimates were developed for two scenarios. The baseline scenario chosen was determined through discussions with the program data flow manager a nd depended on the specific data flow. A CDX use scenario was developed for all data flows. These scenarios included:
Baseline Scenario 1: Estimated cost of the process that was used prior to CDX.
Baseline Scenario 2 : Estimated cost of Program Office devel opment and implementation of an in-house system with similar functionality to CDX.
CDX Use Scenario: Estimated cost of implementing the data flow through CDX.
For baseline scenario 1, the project team used available Program Office cost data to estimate costs associated with the process flow before CDX was implem ented. For baseline scenario 2, the project team worked with the TRI program data flow 2 

### manager to develop a model of what an in-house system with functionality similar to CDX would cost to develop, implement, and operate. Engineers and programmers were involved in this process to help refine the estimates, and other program data flow managers confirmed the estimate. The estimate resulting from this model was applied for all program offices where development of an in-house, CDX-like system was ch osen for the baseline. For the CDX use scenario, the project team examined Program Office cost data to estimate the Program Office costs associated with the process flow during CDX implementation and oper ation. The cost elements identified for each scenario are shown in Exhibit 3-3.

Exhibit 3-3. Cost Elements Considered in Analysis

Baseline Scenario 1 – Pre-CDX Process Cost Elements



### • Contractor resources to process paper (via mail a nd fax), diskette, and other forms of data input used prior to implementing CDX.



### • Contractor resources to assist with quality assuranc e/quality control (QA/QC) and other related functions.



### • O&M costs for existing systems s upporting the data exchange function. Baseline Scenario 2 – In-house, CDX-like System Cost Elements



### • Program Office staff time to oversee sy stem development an d implement ation.



### • Contractor resources to develop and implement the CD X-like application into existing program systems.



### • O&M costs to maintain the system.
CDX Use Cost Elements



### • Contractor resources to int egrate the CDX application into existing program systems.



### • Program Office staff time required to support desi gn, development, and integr ation of CDX into the affected processes.

2 The TRI program was willing to work independently to come up with its own estimate which is why they did it. The CDX team also developed and estimate for the same work. The two estimates were then compared and found to be comparable – and from these a final estimate was developed and then shown to the other Program Offices participating in the study. They accepte d this estimate as reasonable.CDX Business Case Analysis

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### • Estimated future O&M costs. 

### CDX development costs. OEI bore 100 percent of the CDX development costs (i.e., system design, construction, testing, and deployment costs), costs that would be a program investment if a Program Office elected to develop its own in-house CDX-like system.

CDX O&M costs. At the time the analysis was conducted, 100 percent of overall O&M costs for the CDX infrastructure and 90 percent of O&M costs for da ta flows were paid by OEI. OEI is considering Program Offices funding the O&M costs for their data flows and a portion of the CDX infrastructure. For this reason, OEI included an estimated O&M cost to Pr ogram Offices in this study to ensure that cost avoidance was not overestimated in the event that co st-sharing is implemented in future years. O&M costs were based on Office of Information Collectio n (OIC) estimates or, if this was unavailable, an industry standard of approximately 20 percent per y ear of total development and implementation costs. This translated into an imputed O&M cost of appr oximately $100,000 per year for most data flows. O&M costs for individual data flows are included in th e data flow discussions in Sections 4 - 9 of this report.
For the first four data flows analyzed, the project te am developed a model to calculate an estimated costsharing charge for each of the data flows using CDX. First, the team estimated the 2004 CDX O&M costs, then grew those costs at 5 percent per year and applied them across an increasing number of data flows. The increase in data flows was estimated at eight additional data flows per year, which is consistent with trends.

EPA Program Office staff costs. EPA Program Office staff costs were estimated based on the program data flow manager’s estimates of the number of hours personnel devoted to the CDX project. An average hourly rate of $85.00 was applied to level of effort (L OE) estimates. This reflects the average dollar cost of program full-time equivalents (FTEs) in 2005 as doc umented by EPA’s Office of the Chief Financial Officer.


## Step 5 – Develop benefit estimates

In identifying potential monetary benefits, the project team compared the costs of developing an in-house system to the costs of implementing the data flow through CDX, or compared the costs of the process flow prior to CDX to the costs of implementing the data flow through CDX. The approach taken for each data flow is discussed in Sections 4 - 9. OEI used a standard return on investment (ROI) formula to calculate the estimated monetary benefits of using CDX for a data flow (ROI = Net Benefit / Cost of investment). ROIs were developed for most data flows. 

## Step 6 – Develop before and after storyboards

The qualitative aspect of the analysis focused on id entifying operational benefits by comparing the processes before and after CDX in three areas: time liness, data quality, and data accessibility. Although there is certain to be cost savings associated w ith these benefits, an acceptable method to quantify the benefits was not available; thus these savi ngs are not included in the analysis.

Timeliness: In evaluating changes in timeliness, the proj ect team looked at how using CDX has affected the time it takes for information to be submitted and re ndered into a usable form. Specifically, timeliness refers to the amount of time it takes for the EPA Program Office to receive and validate data so that it is ready for use. Timeliness includes impact on turnaro und of data corrections and resubmission as a result of validation issues.CDX Business Case Analysis

March, 2007 12 

### Quality: In evaluating changes in data quality, the pr oject team looked at how using CDX has affected the value, integrity, and overall quality of the data pr ocessed through the data flow. Data quality includes completeness, accuracy, and reliability/error rate.
Accessibility: In evaluating changes in data accessibility, the project team looked at how using CDX has affected the ability of users and data managers to access data (i.e., ease with which the Program Office can make the data available to the broad spectrum of partners or stakeholders who may want to use the data for their own purposes, both inside and outside the Agency).
The project team quantified operational benefits whenever possible (e.g., processing time was 35 minutes for paper and 8 minutes for diskette) but did not assign costs to these benefits. The story boards developed for each data flow are included in Sections 4 - 9. To provide additional insight, each benefit was coded to show the degree of its impact on the Pr ogram Office. The scale used in assessing the impact of benefits and the colors used to code them are as follows:

Rating Scale Used for Assessing Operational Benefits Exceptionally Positive Impact Positive Impact Anticipated Impact No Impact



### The project team worked with the program data flow manager to determine the a ppropriate code to apply to each area of operational benefits : timeliness, quality, and accessibility. 

## Step 7 – Review and confirm results with program data flow manager

The project team coordinated with the program data flow manager to review the process maps, benefit estimates, and story boards of operational benefits for accuracy. The purpose of these discussions was to ensure that all items were presented accurately for inclusion in the benefit report summary. 

## Step 8 – Program ma nagement briefings

The project team prepared detailed briefings for each Program Office that presented the results of the business case analysis of each data flow. The proj ect team incorporated the data flow managers’ comments into the briefing materials. OEI next held a series of EPA management briefings on the results of each data flow analysis. A briefing was held with senior management at each involved Program Office, followed by senior OEI management briefings at EPA Headquarters (HQ). 

## Step 9 – Final benefit report summaries

The project team incorporated comments from the ma nagement briefings and prepared final benefits report summaries for each data flow. These benef it reports served as the basis for this report.CDX Business Case Analysis

March, 2007 13 

# 4. SDWIS Benefit Assessment
4.1 Program Description

All public water system (PWS) suppliers submit co mpliance and enforcement information to EPA for inclusion in the Safe Drinking Water Information Sy stem (SDWIS), as required by the Safe Drinking Water Act (SDWA) Amendments of 1996. Th e Office of Ground Water and Drinking Water (OGWDW), which is responsible for SDWIS, receiv es, maintains, and disseminates the data. SDWIS data are used for the Public Water System Supervision (PWSS) program.



## 4.2 Pre-CDX and Post-CDX Processes

Prior to use of CDX, SDWIS reporting occurred through:

• Electronic transfer of data files via e-mail or File Transfer Protocol (FTP).

• Mailed data in a number of formats including paper files, electronic files on disk, and data tapes.

• Faxed paper files.
Exhibit 4-1 provides an overview of the SDWIS repor ting process prior to the use of CDX. The Primacy Agency responsible for the facility received the da ta and entered the data into a system known as SDWIS/State or other applications that were developed in-house or purchased by the Primacy Agency. The Primacy Agency sent the information to EPA HQ or Regions via mail, fax, or e-mail on paper, data file, diskette, or computer tape. If the data were sent to the Region, the Region reviewed the data for errors, worked with the Primacy Ag ency to resolve any problems, a nd submitted reviewed data to EPA HQ via mail, fax, or e-mail on paper, data file, di skette, or computer tape. Upon data receipt, EPA HQ sent the data to a contractor who prepared the data and entered it into SDWIS/Fed. If there were no problems, the data were processed and published. If there were data problems, EPA HQ notified the submitter; who then corrected and resubmitted the data.CDX Business Case Analysis

March, 2007 14 

### Exhibit 4-1. Overview of SDWIS Process Prior to Use of CDX

OGWDW recognized that this process had several problems and sought to improve the process. The problems with this process included:

The process was slow and time consuming : The complexity of the process and the need to translate from multiple data formats to a single format meant the pr ocess could take many weeks or months to correct. The process was subject to error : The need to translate the data from multiple forms and either hand enter or electronically merge the data meant there were numerous opportunities for error. The process was costly: The process required EPA to expend considerable resources to manage the transfer of data, enter the data, and review the data. The process did not meet security requirements: The electronic transfer of the data frequently did not meet EPA security requirements. This meant that Primacy Agencies and Regions were often forced to rely on the mail to transfer data. This further slowed and occasionally halted the process when security breaches were identified. Primacy Agency collects data EPA HQ/Regions

receive information

Data sent to data entry contractor Paper/Mail, Paper/Fax, E-mail/Data File, Diskette/Mail, Computer Tape/Mail Report logged in

Format?

Convert data into standard format and load data into

SDWIS Federal Organize data and enter into SDWIS Federal
Diskette,

Tape, Electronic Paper

Audit and validate data

Errors / Problems? Send to Regions/Primacy Agency to resolve
errors Yes

Finalize and publish data No Errors / Problems resolved?

Data in SDWIS Federal revised Data not entered into

SDWIS Federal until next quarter

Yes NoCDX Business Case Analysis

March, 2007 15 

### To resolve these issues, OGWDW initiated a project to modernize the SDWIS system by using CDX as the method for data exchange between Primacy Agen cies and EPA. Under the new process, completed in 2005, Primacy Agencies enter data directly in SD WIS/Federal and SDWIS/State and the data are transferred via CDX to EPA HQ. The data are auto matically reviewed for errors through CDX’s data validation process, sent back to the Primacy Agency to resolve any problems, and then finalized and published. Exhibit 4-2 provides an overview of the SDWIS process after implementation of CDX.

Exhibit 4-2. Overview of Post-CDX SDWIS Process



## 4.3 Operational Benefits of SDWIS Use of CDX

Exhibit 4-3 summarizes the operational benefits of SDWIS use of CDX that were identified by the Program Office and rated according to degr ee of impact on data flow operations.

Exhibit 4-3. Summary of Operational Benefits of Using CDX for SDWIS

Timeliness Quality Accessibility
Positive Impact Positive Impact Positive Impact



## SDWIS Data errors can be detected and responded to by Primacy Agencies within minutes or hours. Prior to use of CDX, data review required weeks or months of manual effort. The process flow using CDX supports better and timelier review of data. CDX enabled SDWIS toeliminate a complex, timeconsuming mainframe interface to access data. Data are now accessed easily, which streamlines the cost of responding to data requests. Primacy Agency collects data EPA HQ receives data via

CDX EPA audits and validates data through SDWIS/Fed

Errors? Send to Regions/Primacy Agency to resolve

errors via CDX Yes

Finalize and publish data No Primacy Agency enters data

into CDX

Regions/Primacy Agency review in CDX and send to

EPA via CDXCDX Business Case Analysis

March, 2007 16 

### 4.3.1 Timeliness

Prior to use of CDX, the elapsed time between data being submitted and translated into a single format could be weeks or months. As reporting proceeded on a strict schedule, this meant that there was little time available for detailed data review to identify and resolve errors. As a result, some data were not reported on time or data were ente red with errors. The program data flow manager reported that after CDX was implemented, the elapsed time between da ta being submitted and reviewed shrank from weeks or months to minutes and hours.


### 4.3.2 Data Quality

Prior to use of CDX, data were either reviewed manually by Regions or loaded into SDWIS/Fed from different media, reviewed using a mainframe, and sen t back manually to Primacy Agencies for correction. This process slowed or stopped the review process and could create anomalies in the data from the use of inconsistent data validation and re view processes. After CDX was im plemented, the need for multiple data entry and data translation processes was eliminat ed. Data were entered in a single form and sent directly to EPA HQ. EPA HQ and Primacy Agen cies no longer had to spend resources managing and translating data and could instead concentrate res ources on improving the quality of data. The program data flow manager reported that us ing CDX resulted in better quality in itial data and data that had been more carefully reviewed.


### 4.3.3 Accessibility

Prior to use of CDX, EPA and Primacy Agencies accessed data using a complex, time-consuming mainframe interface. It required c onsiderable effort to obtain data. With the use of CDX for data exchange, EPA and Primacy Agencies can now easily access data and respond to public requests for data. 

## 4.4 Monetary Benefits of SDWIS Use of CDX

The analysis of monetary benefits to SDWIS from using CDX covered the period FY2003 to FY2010, divided into 3 years (FY2003 – FY2005) for devel oping and testing, and 5 years (FY2006 – FY2010) for operation. Based on the review of the processes pr ior to and after use of CDX, the project team anticipated that OGWDW monetary benefits would occu r through use of CDX rather than developing its own in-house, CDX-like secure data exchange mech anism. Use of either of these options would eliminate the need for data entr y and data format translation.
Exhibit 4-4 presents the estimated costs and monetary benefits to the Program Office from use of CDX. Because OGWDW would have eliminated the paper pr ocess even if CDX had not existed, the baseline used for comparison was OGWDW’s developmen t of an in-house, CDX-like system.

Cost Assessment. The total estimated cost of $660,000 for OGWDW developing an in-house, CDX-like system (Row 1) over a period of 3 years included the following cost elements:

• $200,000 estimated spending on design, developmen t, testing and implementation (includes process reengineering and training) of secure Web infr astructure for data exchanges between EPA and Primacy Agencies.

• $420,000 estimated spending on design, developmen t, testing and implementation (includes process reengineering and training) of in-house SDWIS data exchange

• $40,000 estimated internal EPA SDWIS program management and oversight.CDX Business Case Analysis

March, 2007 17 

### Exhibit 4-4. Estimated Costs and Benefits of Using CDX in SDWIS

Estimated Development Cost Estimated Operating Cost Scenario

FY2003–2005 FY2006 FY2007 FY2008 FY2009 FY2010 Total Estimated Cost

1 Cost of In-House, CDX-like System $660,000 $150,000 $150,000 $150,000 $150,000 $150,000 $1,410,000

2 Cost of CDX $315,000 $13,500 $13,500 $109,300 $98,800 $94,300 $644,400

3 Benefit from Using CDX Rather thanDeveloping an InHouse System (Row 1 - Row 2) $345,000 $136,500 $136,500 $40,700 $51,200 $55,700 $765,600



### The O&M cost for an in-house CDX-li ke system (Row 1) was estimated at $150,000 per year for 5 years, resulting in an estimated total of $750,000 fo r O&M. The O&M estimate includes operation and maintenance of the system and expansion of infrast ructure functionality as federal security requirements expanded.
The total estimated cost of $315,000 for implemen ting SDWIS through CDX (Row 2) over a period of 3 years included:

• $247,000 estimated spending on design, developmen t, testing, and implementation (includes process reengineering and training) for the SDWIS/CDX system.

• $68,000 estimated spending to adapt the modernized SDWIS systems to integrate with CDX

The O&M cost for operating SDWIS through CDX (Row 2) was estimated at $13,500 per year for FY2006 and FY2007 to cover the cost to maintain the links from the modernized SDWIS systems to CDX. For FY2008 – FY2010, it was assumed that the SDWIS O&M cost would be comprised of the same $13,500 per year to maintain the links from the modernized SDWIS systems to CDX, plus the SDWIS share of the costs to maintain CDX. Specifically, the SDWIS O&M costs for FY2008 were estimated to be $109,300 ($13,500 + $95,800 for CDX cost share), $98,800 ($13,500 + $85,300 for CDX cost share) for FY2009, and $94,300 ($13,500 + $80,800 for CDX cost share) for FY2010.

Benefit Assessment . Based on a comparison of the costs for developing an in-house, CDX-like system versus using CDX (Row 2 – Row 1), OGWDW a voided expending approximately $345,000 in development costs and between $40,700 and $136,500 per year, or $420,600 over 5 years, in maintenance costs. By this analysis, OGWDW avoided expending an estimated total of $765,600 by using the existing CDX infrastructure.

Return on Investment. In terms of ROI, OGWDW’s estimated net gain of $765,600 divided by the CDX estimated costs of $644,400 results in a 119 pe rcent estimated ROI from using CDX rather than developing an in-house, CDX-like data exchange mechanism.CDX Business Case Analysis

March, 2007 18 

# 5. Lead-based Paint Abatement Program Benefit Assessment
5.1 Program Description

EPA’s Office of Pollution Prevention and Toxics (O PPT) operates a federal training and certification program for lead-based paint abatement activities in target housing and child-occupied facilities. EPA operates its program in states and territories and on Indian tribal land, when these entities are not operating their own EPA-authorized lead-based paint ab atement training program. This program requires training, certification, and adherence to specific work practice standards when conducting lead-based paint abatement activities, which include inspection, risk assessment, and abatement. Companies that perform lead-based paint abatement activities must a pply to EPA for company certification and provide advance notice of future abatement actions. Trai ning providers must provide EPA notification of upcoming training events.



## 5.2 Pre-CDX and Post-CDX Processes

CDX is used in two major lead-based paint abatement program processes:

1) Applications for certification to perform abat ement, and payment of certification fees through Pay.Gov. 2) Notifications of forthcoming abatement actions, upc oming training classes, and attendance at training sessions.
Prior to use of CDX, both processes involved submis sion of hard copy forms to EPA and manual data entry, review, and correction. Exhibit 5-1 provides an overview of the process before use of CDX

. 

### Lead abatement companies or training providers obtai ned the relevant form from the EPA lead abatement Web site or another source such as EPA or state offi ces, completed the form, and sent the form to EPA either via facsimile or by mail. The hard copy fo rm was received at EPA and forwarded to a data entry contractor. The contractor then reviewed the file and entered the data in th e lead-based paint abatement program database. If there were problems in reading the data, the contractor would contact the submitter and obtain clarification. The data were then ente red into the program data base and the process was completed.CDX Business Case Analysis

March, 2007 19 

### Exhibit 5-1. Overview of Pre-CDX Lead-based Paint Abatement Notification and Certification Process

OPPT recognized that this process had several probl ems and sought to improve the process. Problems with the process prior to using CDX included:

• The process was time consuming: The process required up to 10 days for the EPA contractors to receive and enter the data and send it to the Regions.

• The process was subject to error: The need to translate the data from hard copy forms and hand enter the data meant there were numerous opportunities for error. Faxed reports were difficult to read and led to transcription errors and data entry errors.

• The process was costly: The process required EPA to expend considerable resources on contractor support to enter, review, and correct the data



### . In 2005, EPA initiated a project to provide an electr onic reporting system for lead abatement notification and certification through CDX. Exhibit 5-2 s hows the process after CDX was implemented.
Companies were required initially to register and obtain a CDX ID; the process of obtaining a CDX IDwas later changed to open registration as a streamlining measure. With CDX in place, companies go online and enter data into the appropriate form el ectronically through CDX. The CDX Web page has numerous automatic error checks and prevents compan ies from sending incomplete or inaccurate data. After the form is completed, it is automatica lly sent to EPA HQ and forwarded to the Region. Company completes application or notification form Fax or mail hard copy form to EPA EPA receives and log in

forms EPA sends forms to contractor

( dail y)

Contractor logs in and distributes forms to data

entry clerk Contractor enters data into the lead program system Data review

Notify submitter

and correct
errors Data complete and sent to Region Errors?

Yes NoCDX Business Case Analysis

March, 2007 20 

### Exhibit 5-2. Overview of Post-CDX Lead-based Paint Abatement Notification and Certification Process



## 5.3 Operational Benefits of Lead-base d Paint Abatement Program Use of CDX

Exhibit 5-3 summarizes the operational benefits of lead-based paint abatement program use of CDX that were identified by the Program Office and rated according to degree of impact on data flow operations. It should be noted that at the time this benefits anal ysis was performed, CDX had recently been integrated into the lead-based paint abatement system and fewe r than 100 forms had been received through CDX. Therefore, the results reported are impressions from the first forms received by EPA after CDX implementation.

Exhibit 5-3. Summary of Operational Benefits of Using CDX in the Lead-based Paint Abatement Program

Timeliness Quality Accessibility Ancillary Benefit
Positive impact Positive impact No Impact Positive impact

## Leadbased PaintAbatement Prior to use of CDX, form processing required an average of 10 days. Forms are now entered by the applicants directly into the system on the Web, reducing processing time to an average of 2 days. Forms submitted by fax or mail were often either illegible or incomplete, delaying data entry. With CDX, data are quality checked at the time of entry, increasing accuracy and reducing the need for corrections. There was insufficient program use at the time of analysis to identify accessibility benefits. Companies can access Pay.Gov through CDX to make payment to the Treasury when applying for certification. Prior to CDX implementation, payment was a separate process.



### 5.3.1 Timeliness

Form processing time was reduced from an average of 10 days to 2 days in most cases. Prior to the implementation of CDX, processing forms could take several days from the EPA receipt of the form to completion of the data record. The data entry contr actors frequently could not read the faxes and had to contact submitters to clarify information. It was often difficult to reach the appropriate person by telephone, as many forms came from small business without regular office support. As a result, it could be days before a form could be co mpleted with all questions resolved. Register for CDX Log in to CDX Enter data Data automatically quality checked and

sent to EPA HQ

electronically

EPA HQ receives

electronic form Record sent to the Region via CDXCDX Business Case Analysis

March, 2007 21 

### After CDX was implemented, forms are now complete d directly by the firm or training provider and entered into the system via the Web instantaneously. This means that the data are typically available for action by enforcement or review within 2 days.


### 5.3.2 Data Quality

Prior to implementation of CDX, most notification forms were sent to EPA via facsimile. The forms were difficult to read and, as a resu lt, data that contained undetected errors was entered into the system. With CDX in place, submitters enter data into an el ectronic form on the Web. The form is automatically error checked at the time of data entry, and the s ubmitters are asked to correct errors before form submission. After errors are corrected, the forms are sent directly to EPA via CDX. There is no separate data entry. The result is fewer data errors and overall improved data quality.


### 5.3.3 Accessibility

There was insufficient program use at the time of the analysis (i.e., fewer than 100 forms had been processed through CDX) to confirm observed impacts in the area of data accessibility.


### 5.3.4 Ancillary Benefit

The Program Office cited the integration of CDX with Pay.Gov as an ancillary benefit of using CDX. Pay.Gov is the system companies use to make paymen t to the Treasury when applying for certification. Prior to use of CDX, applicants had to pay the fees separately. CDX provides direct access to Pay.Gov by providing a link for an applicant to leave CDX and go dir ectly to Pay.Gov. This benefit is included as an operational benefit of CDX but is not considered a monetary benefit, since the actual functionality to make this payment is not part of CDX. Thus, while CDX has automated this functionality and users perceive it as part of the same application, it was not included as part of CDX’s direct costs and benefits in Section 5.4. 

## 5.4 Monetary Benefits of Lead-base d Paint Abatement Program Use of CDX

The timeframe considered for the lead-based pain t abatement program was the period FY2005 through FY2013, composed of 2 years (FY2005 – FY2006) for development and testing, and 7 years (FY2007 – 2013) for operation. The project team reviewed the processes prior to and after use of CDX to determine how to best assess monetary benefits for the lead -based paint abatement program. A Program Officedeveloped system was not considered a realistic scen ario here because it was immediately recognized by all as more costly than the CDX alternative. Therefor e, the monetary benefits for this data flow were estimated by assessing the difference between the cost of the pre-CDX process, which involved transmission of forms via fax with manual data en try, and electronic data entry through CDX.
Exhibit 5-4 summarizes the results of the cost assessment in terms of a comparison of pre-CDX and postCDX data entry costs. Exhibit 5-5 presents the estimated development and maintenance costs for implementing CDX into the lead-based paint abatement data flow.CDX Business Case Analysis

March, 2007 22



### Exhibit 5-4. Pre-CDX Data Entry Costs Compared to Post-CDX Data Entry Costs for the Lead-based Paint Abatement Program

1 2 3
Estimated No. of Certifications and Notifications Per Year Estimated Cost per Form Estimated Annual Cost to Enter Data ( Column 1 x Column 2 )

CERTIFICATION APPLICATIONS SUBMITTED

1 Total pre-CDX mailed/faxed certification applications 644 $38.15 $24,577

2 Total post-CDX electronic certification applications 108 $0.00 $0.00

NOTIFICATIONS SUBMITTED

3 Total pre-CDX fax/mailed notifications 4,878 $5.08 $24,782

4 Total post-CDX electronic notifications 120 $0.00 $0.00



### Exhibit 5-5. Estimated Costs Associated with Use of CDX in the Lead-based Paint Abatement Program

Cost Element Estimated Cost

1 CDX development cost to the Program Office $130,000

2 Integration costs incurred by Program Office $ 30,000

3 Program Office FTE costs associ ated with CDX implementation $ 3,000

4 O&M costs for CDX maintenance ($18,000 year x 7 years = $126,000) $126,000

5 Total estimated development and maintenance costs $289,000



### Cost Assessment. As shown in Exhibit 5-5, Row 4, CDX maintenance costs were estimated at $18,000 annually. These costs include internal CDX-relate d maintenance including review of system data, meetings with OEI staff to discuss general CDX issu es, and management reporting concerning CDX.

Benefit Assessment. As shown in Exhibit 5-4, the cost to the Program Office to enter data from the notification or certification forms varies from approxima tely $5 to approximately $38, whereas the cost to enter and receive and process a form submitted through CDX is effectively $0. This means that the Program Office anticipates avoiding 100 percent of the previous costs estimated for manual processing and data entry for submissions that come in throu gh CDX. At the time of the analysis, only a small number of companies were using the lead-based paint abatement program via CDX. The project team and Program Office concurred that results were too pr eliminary at that time to calculate a meaningful return on investment.
The Program Office anticipates that the most signi ficant benefits from CDX use beginning in FY2010 with an expected influx of new respondents. At the time of the analysis, the Program Office anticipates issuing a new rule in 2008 that would lead to a subs tantial increase in the size of the regulated community for lead-based paint abatement starting in FY2010. Exhibit 5-6 illustrates this scenario, showing the associated potential benefits to the Program Office dur ing FY2010 – FY2013. As shown in the exhibit, the increase in submissions would be expected to be the highest in FY2011, falling somewhat in FY2012CDX Business Case Analysis

March, 2007 23 

### and FY2013. The total number of projected submissions per year is shown in Exhibit 5-6; the estimated benefits shown in Exhibit 5-6 are based on 75% of the projected submissions being received via CDX 3



### . Under this scenario, use of CDX could provide the lead-based paint abatement program potential monetary benefits totaling as high as $9.5M between FY2010 and FY2013.
Exhibit 5-6. Potential Lead Abatement Monetary Benefits from Use of CDX (w/estimated 75% of total anticipated submissions using CDX)

3 The Program Office does not know how many submissions w ill come in via CDX because many of the entities making submissions are small and/or work in the field all day without ready access to the In ternet. For the purposes of this report, the Program Office felt an assumption that 75% of all respondents w ill submit through CDX was reasonable – but stressed that actual use could turn out to be much higher or lower and thus affect the resulting monetary benefit. 150,000

100,000 Submissions

Each Year Using CDX

Fiscal Year 2005 2006 2007 2008 2009 2010 2011 2012 $1,000,000 $3,000,000

$2,000,000 $4,000,000

= Estimated Cost without CDX = Estimated Cost with CDX $3.3 M Benefit $4.1M

$2.1M

2013 With 127,000 Submissions Using CDX In 2011 155,000

79,000 Benefits From Submissions

Using CDX

50,000

25, 000

5,700 6,300 6,900 7,600 8,300 9,200CDX Business Case Analysis

March, 2007 24 

# 6. UCMR Benefit Assessment
6.1 Program Description

The Unregulated Contaminant Monitoring Rule (UCM R) is the regulatory mechanism used to describe procedures to report, evaluate, and prioritize contam inants on the Drinking Water Contaminant Candidate List. This information is used by EPA’s Office of Ground Water and Drinking Water (OGWDW) to help ensure that future decisions on drinking water st andards are based on sound science. Every 5 years, public water systems (PWSs) submit da ta on unregulated contaminants. At the time of this analysis, the database used for data submission was termed UCMR; the name of the database was later changed to SDWARs (Safe Drinking Water Accession and Review System).



## 6.2 Pre-CDX and Post-CDX Processes

Exhibit 6-1 provides an overview of the UCMR data exchange process prior to implementing CDX. As shown in Exhibit 6-1, data were sent to EPA from PWSs in a variety of forms, including paper, computer tape, diskette, and laboratory slips, and submitted via mail or facsimile . EPA forwarded the data to a contractor for processing. To convert the data into a consistent electronic format , some data were entered manually and other data were convert ed from its native form into a co mmon electronic form. Each data form that was submitted required EPA to construct a data converter to c onvert it into the common format. Since data forms were not known until the data were submitted, the UCMR program was not able to acquire the appropriate converters un til data from all public water suppliers were acquired. This slowed the data conversion process. After the data had b een converted into a common electronic format, the completed files were sent to the UCMR quality assurance (QA) Team. The UCMR QA Team manually reviewed the data on screen to identify errors. These errors were then sent back to the appropriate PWS for correction.CDX Business Case Analysis

March, 2007 25 

### Exhibit 6-1. Overview of Pre-CDX UCMR Process

Since CDX has been implemented, the UCMR reporti ng process has been dramatically streamlined. The UCMR process using CDX is illustrated in Exhibit 6-2

. With CDX in place, public water suppliers log onto the CDX system and enter data directly into th e system. Numerous automated error checks are built into CDX to provide immediate validation of the data. Data files are then sent directly to EPA via CDX. Data are reviewed by the UCMR QA Team using au tomated routines. Errors are resolved via on-line communication with the public water suppliers who s ubmitted the data. When errors are found, the data are sent back to the PWS with notes identifying the erro rs. The PWS then resolves the errors and returns the corrected data via CDX. PWS collects data EPA HQ receives information

Data is sent to

data entry contractor Paper/Mail, Paper/Fax, E-mail/Data File, Diskette/Mail, Computer Tape/Mail Report logged in
as received

Format? Organize data and enter into program data system Diskette,

Tape, Electronic Paper

Send data to UCMR QA Team for review

Problems? Send to PWS to

resolve errors Yes

Finalize and publish data No Data is revised and entered into

program data system Convert data into standard format and load data into

program data system Review data and acquire appropriate data converters

Multiple iterationsCDX Business Case Analysis

March, 2007 26 

### Exhibit 6-2. Overview of Post-CDX UCMR Process



## 6.3 Operational Benefits of UCMR Use of CDX

Exhibit 6-3 summarizes the operational benefits of UCMR use of CDX that were identified by the Program Office and rated according to degr ee of impact on data flow operations.

Exhibit 6-3. Summary of Operational Benefits of Using CDX for UCMR Reporting

Timeliness Quality Accessibility Ancillary Benefit Exceptionally Positive Impact Exceptionally Positive Impact Exceptionally Positive Impact Exceptionally Positive Impact 

## UCMR

Use of CDX reduced data preparation time from 5-7 years to 90- 120 days. CDX resolved data completeness and quality issues. CDX offers secure, integrated repository for states, labs, PWSs, and EPA. Some PWSs have reported that the use of CDX reduced their data entry time by as much as 90%.



### 6.3.1 Timeliness

Due to the complexity of converting information into a usable format, before the implementation of CDX data collections could take 5 to 7 years to compile and correct. After CDX, UCMR data are available on the program database within 90 to 120 days of receipt . During this time, the data undergo quality control review by the PWS to fix any remaining errors. This remarkable improvement in timeliness is a result of the automated data validation used while PWSs are entering data directly into CDX. PWS collects data EPA receives information

QA Team reviews data

Problems? Send to PWS to resolve errors via CDX Yes

Quality control review performed by PWS via

CDX; data finalized

and published No PWS enters data into CDX

PWS reviews and corrects and sends to EPACDX Business Case Analysis

March, 2007 27 

### 6.3.2 Data Quality

UCMR data quality has improved drama tically with use of CDX. Before using CDX, the diversity of data formats (e.g., magnetic tape, VAX tapes, floppy disks, paper) made error correction difficult and costly. CDX provides UCMR with a standard data format from data entry onward. Pre-populated selection lists and automated business rule validation allow for immediate and inexpensive correction of errors. Furthermore, prior to CDX, due to the data completeness and data quality issues, EPA used only a cross-section of data to establish a data set that w as nationally representative. With CDX, EPA can now use a much broader cross-section of data from submitters, yielding a dataset that is more representative of reality, and supports better environmental decisions c oncerning enforcement and regulation. In addition, CDX offers an automated audit trail of receipt, m odifications, and approvals; automated authentication and access controls with logging; and real-tim e e-mail notifications of exceptions.


### 6.3.3 Accessibility

As a result of the dramatic improvements in time liness, CDX was able to substantially improve accessibility to the UCMR data. Prior to CDX impl ementation, the data took so long to assemble (5-7 years) that the data were rarely available in a complete form. After CDX was implemented, OGWDW created an integrated data repository to provide pub lic access to UCMR data via the Web. The data are downloaded from CDX to the data repository; there is no public access to CDX itself. The data are generally available in the repository within 90 – 120 days of receipt by EPA.


### 6.3.4 Ancillary Benefit

Although this study focused exclusively on benefits to the Program Offices for the data flows examined, there were some benefits to other users so striking as to merit inclusion in the report. In this case, some PWSs reported as much as a 90 percent reduction in data entry time using CDX. 

## 6.4 Monetary Benefits of UCMR Use of CDX

The study period for UCMR covered four multi- year data collection periods from FY1987 through FY2010. (Note that no data collection occurred in FY2000.) CDX development occurred during the FY2001–FY2006 collection period. Based on the review of the processes prior to and after use of CDX, the project team identified two major areas where OGWDW monetary benefits were likely to occur:

• Use of CDX eliminated the need for data entry and data format translation.

• Use of CDX avoided the cost of OGWDW developi ng its own secure, data exchange method.

Exhibit 6-4 summarizes the results of the cost assessment and presents the estimated monetary benefits to the Program Office from use of CDX. Key assumptions made for this analysis included:

• Costs for piloting and prototyping UCMR were included.

• Cost does not include development of the accompanying SDWARS database.CDX Business Case Analysis

March, 2007 28 

### Exhibit 6-4. Estimated Costs and Benefits of Use of CDX in UCMR

1st Data Collection 1987-1992 2nd Data Collection 1993-1999 3rd Data Collection 2001-2005 4th Data Collection 2006-2010 Estimated Total Cost

OGWDW Development of In-house, CDX-like System

1 Development costs $ - $ - $ 995,000 $ - $ 995,000

2 O&M costs $ - $ - $ 495,000 $ 495,000 $ 990,000
3 Total estimated cost for CDX-like system $ - $ - $ 1,490,000 $ 495,000 $1,985,000

Using CDX for UCMR

4 CDX development costs to the Program Office $ - $ - $1,292,000 $ - $ 792,000

5 CDX O&M $ - $ - $ 750 $601,100 $ 601,850

6 Total estimated cost of using CDX $ - $ - $ 1,292,750 $601,100 $ 1,893,850

Benefit Estimate

7 Estimated benefit of using CDX over development of CDX-like system (Row 3 – Row 6) $91,150



### Cost Assessment. The project team worked with the program data flow manager and other Program Office staff to estimate as accurately as possible the po tential cost of developing a CDX-like system. These costs, estimated at $995,000 (Row 1), were composed of the following cost elements:

• $495,000 for UCMR base development costs.

• $500,000 for development of Web forms and business rules for data validation. It was estimated that O&M costs for sustaining a CDX-like system (Row 2) would run at $495,000 per 5- year collection period.
The CDX development costs, estimated at $792,000 (Row 4), included the following elements:

• $75,000 for archiving, registration, login and launch features.

• $17,000 for system design and documentation.

• $200,000 for rule validation.

• $1,000,000 to develop Web fo rms and business rules.
UCMR was one of the first programs to adopt C DX, therefore, UCMR’s CDX development costs included a significant amount of research and deve lopment (R&D) costs not experienced by programs that adopted CDX later. The R& D costs associated with development of CDX were estimated at $500,000 of the Program Office’s estimated CDX de velopment costs for the UCMR data flow. These costs would not be experienced by programs that adopted CDX after UCMR, as other programs would be able to benefit from reusable sy stem components developed earlier.CDX Business Case Analysis

March, 2007 29 

### As noted in Section 2, one of the study assumptions was that Program Offices would potentially share O&M costs for CDX in the future, so these costs were in cluded in the analysis. As shown in Row 5, most of the estimated $601,850 O&M costs are projected to occur in the 4 th 

### collection period.

Benefit Assessment. The primary monetary benefit gained fro m using CDX for the UCMR data flow rather than developing an in-house, CDX-like system was estimated at $91,150 (Row 7). Without the R&D costs included in the CDX development costs, th e monetary benefit would have been estimated at $591,150. Since future programs would benefit from reusable components developed for the UCMR data flow and not encounter the R&D costs, the higher be nefit is more representative of what these programs could anticipate.

Return on Investment . In terms of the ROI, OGWDW’s estimat ed net gain of $91,150 (Row 7) divided by the estimated cost of $1,893,850 (Row 6) for CDX development and maintenance results in a 4.8 percent estimated ROI from using CDX rather than developing an in-house, CDX-like system. Without the R&D costs, the ROI would have been an estimated 42 percent. Since future programs would benefit from reusable components developed for the UCMR da ta flow and not encounter the R&D costs, the 42 percent ROI is more representative of what these programs could anticipate.CDX Business Case Analysis

March, 2007 30 

# 7. TRI Benefit Assessment
7.1 Program Description

The Toxic Release Inventory (TRI) is a publicly available EPA database that contains information on toxic chemical releases reported annually by certain c overed industry groups and federal facilities. TRI, managed by EPA’s Office of Information Analysis and Access (OIAA), was established under the Emergency Planning and Community Right to Know Act (EPCRA) and expanded by the Pollution Prevention Act (PPA) of 1990. EPCRA’s primary purpose is to inform communities and citizens of chemical hazards in their areas.
Sections 311 and 312 of EPCRA require businesses to report the locations and quantities of chemicals stored on site to state and local governments in orde r to help communities prepare to respond to chemical spills and similar emergencies. EPCRA Section 313 re quires EPA and the states to annually collect data on releases and transfers of certain toxic chemicals from industrial facilities, and make the data available to the public. EPA compiles the TRI data each year and makes it available through several publicly available data access tools, including the TRI Explorer and Envirofacts.



## 7.2 Pre-CDX and Post-CDX Processes

Prior to implementing CDX, TRI reporting occurred via pa per or diskette. Exhibit 7-1 illustrates the TRI data flow process prior to use of CDX. As shown, f acilities prepared paper or diskette versions of their reports. Diskette versions were pr epared using TRI-ME software. F acilities sent the reports to the TRI data processing center. Paper files were reviewed and entered manually into the TRIS (the TRI data system). Electronic files were loaded directly. Electronic files were required to be accompanied by a certification page that had been signed by the facility’s Certifying Official. Often, the signature form would not accompany the diskette, and further co mmunication had to occur between the TRI data processing center and the facility to obtain the signed form.CDX Business Case Analysis

March, 2007 31 

### Exhibit 7-1. Pre-CDX TRI Process

With CDX in place, facilities complete their forms on-line using TRI-ME and send them directly to the Reporting Center via CDX. Exhib it 7-2 shows the TRI process after using CDX. The process is quick, easy, and secure. Facilities enter data in TRI-ME via CDX, where data are available for review and validation by States. Facility collects data

Facility enters data in TRI-ME Facility completes forms and sends data to state

TRIS Format?

Diskette,

Tape, Electronic Paper Organize data and enter into TRIS

Review data Correct Data

Problems? Yes

Finalize and publish data No State receives data and updates its state system. State does not send data to TRISCDX Business Case Analysis

March, 2007 32 

### Exhibit 7-2. TRI Process after CDX Implementation



## 7.3 Operational Benefits of TRI Use of CDX

Exhibit 7-3 summarizes the operational benefits of TRI use of CDX that were identified by the Program Office and rated according to degree of impact on data flow operations.

Exhibit 7-3. Summary of Operational Be nefits of Using CDX for TRI Reporting

Timeliness Quality Accessibility Ancillary Benefit

Exceptionally Positive Impact Exceptionally Positive Impact Positive Impact Positive Impact 

# TRI • With use of CDX, public data release is possible 7-8 months earlier than previously.



### • Data processing time

was reduced from 35 minutes (for paper submission) or 8 minutes (for diskette submission) to 4 minutes using CDX. Error rates prior to using CDX were 10.4% for paper processing and 2.1% for diskette processing. Use of CDX reduced the error rate to 0.6% With the implementation of CDX in the TRI data flow, states are able to generate reports and can view, review, and validate data earlier in the process. Industry reports up to a 2-hour time savings from CDX’s electronic signature feature. Facility collects data Facility entersdata in TRIME

TRIS

QA Data and Review Correct Data

Problems? Yes

Finalize and publish data No CDX States view, review, and validate dataCDX Business Case Analysis

March, 2007 33 

### 7.3.1 Timeliness

The introduction of CDX brought significant benefits to the TRI program in the area of timeliness. Before the implementation of CDX, complete processing time for loading data into TRIS after receipt at EPA was 35 minutes for paper submissions and 8 minutes for diskette. With CDX, the processing time shrank to 4 minutes.
CDX had a major impact on the availability of the TR I public data release (PDR), which contains the official government figures on toxic releases. PDR is u sed by a large segment of the public to view the TRI data. The PDR was widely disseminated each year in compliance with legal requirements to produce an annual report. Before CDX, the PDR was completed by June of the year after the data were received and a preliminary file was returned to the states for review in the following October or November. If all submitters would use CDX, the TRI program would be able to submit the PDR 7 months earlier, and the preliminary file could be sent to the states 1-2 months earlier.


### 7.3.2 Data Quality

Prior to the use of CDX, the error rates for TRI submitted data varied from 10.4 percent for paper submissions to 2.1 percent for diskette submissions where TRI-ME was used to prepare the data. With use of CDX, all submissions are electronic and the error rate has fallen to 0.6 percent.
Before use of CDX, there were a higher number of Notices of Significant Errors (NOSEs) due to missing signatures for Form R’s and Form A’s submitted via pape r and diskette. With CDX’s eSignature feature, forms cannot be submitted without signatures, resu lting in fewer NOSEs to respond to, and burden reduction for both EPA and facilities who submit data.


### 7.3.3 Accessibility

The implementation of CDX for TRI had a significant impact on data accessibility. Most importantly, before use of CDX, the states had no direct access to EPA’s TRI data. With the implementation of CDX in the TRI data flow, states are able to generate re ports and can view, review, and validate data early in the process. With CDX in place, states receive the preliminary file within 2 weeks of the submission deadline as compared to several months later wit hout CDX. This saves more than 1 hour of EPA contractor time and 25 hours of EPA time previously required to prepare and send the e-mails with the preliminary files.


### 7.3.4 Ancillary Benefits

Although this study focused on benefits to the Program Offices for the data flows examined, there were some benefits to other users so striking as to merit inclusion in the report. In this case, industry reported as much as a 2-hour time savings from CDX’s electronic si gnature feature. Considered in the context of saving 2 hours of staff time for each of the estimated 25,000 facilities who submit TR I data, this benefit is substantial. 4

4 Since the completion of the study, CDX has implemented an “ outbound” TRI data flow sending industry submissions to EPA back out to the appropriate states over the Exchange Network. This process can save both industr y and states time and money. Industry reduces its reporting burde n because it no longer sends d uplicate reports to the states. And states trim the money an d time they spend collecting and maintaining their own TRI data be cause they can get it from EPA using the Network and CDX.CDX Business Case Analysis

March, 2007 34 

## 7.4 Monetary benefits of TRI Use of CDX

The assessment of TRI before and after using C DX covered a period of 7 years, from FY2002 through FY2008. This period includes a 2-year development period (FY2002 – FY2003) and 5 years of operation (FY2004 – FY2008). Based on review of the processes prior to and after use of CDX, the project team identified two major areas where OIAA monetary benefits were likely to occur:

• Use of CDX eliminated the need for data entry and data format translation.

• Use of CDX avoided the cost of developing an in-house secure, data exchange method similar to CDX.

Exhibit 7-4 summarizes the results of the benefit assess ment and presents the estimated monetary benefits to the Program Office from use of CDX. As shown, the analysis considered how three different scenarios were likely to evolve over the analysis period:

• Continuing submission of data via paper and diskette,

• OIAA development of an in-house system w ith equivalent functionality to CDX, and

• Use of CDX for TRI data submission.

Exhibit 7-4. Estimated Costs and Benefits of CDX Use in TRI

Year FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total
Estimated costs of TRI reporting via paper and diskette

1 Paper submissions $644,574 $585,874 $520,590 $520,590 $49 5,800 $495,800 $47 1,010 $3,734,238

2 Diskette submissions $134,592 $122,336 $115,340 $115,340 $116,800 $116,800 $118,260 $839,468

3 Obtaining missing signatures on data submissions $11,394 $11,394 $11,394 $11,156 $11,156 $10,918 $10,918 $78,327

4 EPA FTE costs $11,000 $11,000 $11,000 $11,000 $11,000 $11,000 $11,000 $77,000

5 Total for data submission via paper or diskette $801,559 $730,603 $658,323 $658, 085 $634,755 $634,518 $611,188 $4,729,032

Estimated Costs for OIAA development of in-house, CDX-like system

6 Base development $247,500 $247,500 $0 $487,400 $0 $0 $0 $982,400

7 O&M $0 $49,500 $99,000 $99,000 $196, 480 $196,480 $196,480 $836,940

8 Paper submissions $556,677 $479,352 $371,850 $371,850 $37 1,850 $247,900 $12 3,950 $2,523,429

9 Diskette submissions $127,690 $92,536 $80,300 $73,000 $65,700 $36,500 $21,900 $497,626CDX Business Case Analysis

March, 2007 35 

### Exhibit 7-4. Estimated Costs and Benefits of CDX Use in TRI

Year FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total

10 CDX-like system submissions $6,205 $18,531 $22,500 $26,250 $30, 000 $48,750 $60,000 $212,236

11 EPA FTE costs $55,000 $11,000 $11,000 $11,000 $11, 000 $11,000 $11,000 $121,000

12 Total to develop CDX-like system $993,072 $898,419 $545,371 $935, 542 $523,690 $493,970 $413,330 $5,173,631

Estimated OIAA costs for implementation and use of CDX

13 O&M $0 $0 $14,570 $24,105 $38,2 84 $138,642 $122,637 $338,238

14 Paper submissions $556,677 $479,352 $371,850 $371,850 $37 1,850 $247,900 $12 3,950 $2,523,429

15 Diskette submissions $127,690 $92,536 $80,300 $73,000 $65,700 $36,500 $21,900 $497,626

16 CDX submissions $6,205 $18,531 $22,500 $26,250 $30, 000 $48,750 $60,000 $212,236

17 EPA FTE costs $55,000 $11,000 $11,000 $11,000 $11, 000 $11,000 $11,000 $121,000

18 Total for use of CDX $745,572 $601,419 $459,762 $366, 599 $353,387 $436,132 $339,487 $3,692,529

Estimated monetary benefit from using CDX

19 Estimated benefit of using CDX
vs

paper/ diskette $55,987 $129,185 $158,104 $151,88 0 $117,921 $151,726 $271,700 $1,036,504

20 Estimated benefit of using CDX
vs

developing a CDXlike system $247,500 $297,000 $84,431 $562, 295 $158,196 $57,838 $73,843 $1,481,102



### Cost Assessment . Estimates were based on the anticipated number of facilities that would use CDX or an in-house CDX-like system to report, and the number that would likely continue to report using diskette or paper. For continued use of paper and diskette submission, the project team included the estimated costs of following up with facilities to collect missing signatures on the forms that accompanied the data. Data entry costs were estimated based on costs to ente r data at the time of the analysis. Costs included contractor costs and the EPA FTE costs to develop a nd maintain the data entry system. Tables showing detailed cost breakdowns for TRI cost est imates are contained in Appendix A.

Benefit Assessment . Comparing continued use of paper reporting with electronic reporting either through CDX or an in-house, CDX-like system, the TRI program has avoided expending more than $1 million per year in data processing of paper and diske tte. Comparing the use of CDX versus developing an in-house, CDX-like system, OIAA has avoided e xpending approximately $1.5 million by using CDX rather than developing its own system.CDX Business Case Analysis

March, 2007 36 

### As shown in Appendix A, Table A-3, the Program Office estimated per-form submission costs for TRI to be $24.79 for paper submission, $1.46 for diskette submission, and $.75 for submission via CDX. On this basis, by using CDX in TRI, OIAA avoids e xpending $24.04 in processing costs for each paper submission and $.71 in processing cost s for each diskette submission.

Return on Investment . The ROI for TRI was based on comparing use of CDX versus continued use of paper reporting. OIAA’s investment in CDX was ca lculated as $382,238 by adding the total estimated O&M costs shown in Row 13 ($338,238) and the add itional portion of estimated EPA FTE costs incurred because of the need to supervi se CDX development in FY2002 extr apolated from Row 17 ($55,000 - $11,000 = $44,000). The CDX investment estimate di d not include the TRI operational processing costs that would have been incurred in the absence of using CDX. OIAA’s estimated net gain of $1,036,504 (Row 19) divided by the estimated Program Office investment of $382,238 results in a 271 percent estimated ROI from using CDX rather than contin ued use of paper reporting. An ROI based on a comparison of OIAA using CDX versus developing an in-house, CDX-like system, would have been estimated at 387 percent ($1,481,102 [Row 20] / $382,238).CDX Business Case Analysis

March, 2007 37 

# 8. e-NOI Benefit Assessment
8.1 Program Description

EPA regulates storm water runoff from construction sites that disturb an acre or more of land, through the National Pollutant Discharge Elimination System (N PDES). EPA is the permitting authority in five states, territories, and tribal land. State environmental agencies implement the NPDES permitting program in 45 states. Storm water discharges from regulated construction s ites are covered by EPA’s Construction General Permit. Constr uction site operators are required to file a Notice of Intent (NOI) form to obtain coverage under this permit. The NOI is the primary document used by the EPA to monitor and enforce compliance with the NPDES storm water re quirements. At the conclusion of the construction project, operators file a Notice of Termination ( NOT) to end coverage under the Construction General Permit. EPA’s Office of Wastewater Manageme nt (OWM) manages NOI and NOT reporting. The reporting system was termed “e-NOI” after going electronic through CDX.



## 8.2 Pre-CDX and Post-CDX Processes

Exhibit 8-1 illustrates the NOI and NOT data flow befo re implementation of CDX. Prior to use of CDX, construction site operators would send completed paper copies of the NOI and NOT forms to EPA HQ. These forms were then transferred to a contractor to process. Forms were manually sorted, complete forms were entered into the tracking system, and incomp lete forms were returned to the operator by mail requesting corrections. Corrections were returned via mail and matched up with the original paper record and entered into the system. This process relied h eavily on manual sorting and screening of forms as well as manual data entry into the tracking system.CDX Business Case Analysis

March, 2007 38 

### Exhibit 8-1. Pre-CDX e-NOI Process

After the implementation of CDX in the NOI process fl ow, the process has been dramatically streamlined as shown in Exhibit 8-2.

Exhibit 8-2. Post-CDX e-NOI Process

With CDX in place, construction site operators log onto the system and enter data directly through CDX. Numerous, automated error checks are built into the C DX data entry system to improve the quality of the data. After the data are certified by the operator, CD X delivers the data directly into the e-NOI database. 

## 8.3 Operational Benefits of e-NOI Use of CDX

Exhibit 8-3 summarizes the operational benefits of e-NOI use of CDX that were identified by the Program Office and rated according to degree of impact on data flow operations. Finalize and publish data Construction site operator enters data directly into CDX EPA HQ/receives information

via CDX Construction site operator

completes

forms Send hard copy forms to EPA HQ Send forms to data entry contractor EPA log in form receipt

Contractor organizes data and enters into Program data s y stem

Problems? Send to construction site operator to resolve errors Yes

Finalize and publish data No Data revised and entered into Program data system Contractor reviews dataCDX Business Case Analysis

March, 2007 39 

### Exhibit 8-3. Summary of Operational Benefits of Using CDX for e-NOI Reporting

Timeliness Quality Accessibility Ancillary Benefit

Exceptionally positive impact Exceptionally positive impact Exceptionally positive impact Exceptionally positive impact 

# e-NOI Use of CDX haseliminated approximately 33 days of processing time to obtain a permit. Administrative error rates were reduced from 80% to near 0%. Current and historical data are readily available to the Regions and public for the first time, via CDX download to the NPDES Web site. Data for enforcement rose from 30% availability to 95% availability.



### 8.3.1 Timeliness

Before CDX, there was a persistent backlog in th e system. This backlog sometimes exceeded 1,000 forms. On average, 33 days elapsed from the ti me a form was mailed until it was received by EPA, processed, and entered into the system. For the constr uction site operators that use the e-NOI system via CDX, the 33-day processing time has been eliminated. W ith CDX in place, data are entered directly into the system via CDX and there is no processing time.


### 8.3.2 Data Quality

Data quality has dramatically improved with the implem entation of CDX. Before CDX, 80 percent of the submissions contained errors that needed resolution. With CDX’s automatic data checks at time of data entry, forms are nearly always complete and error-free.


### 8.3.3 Accessibility

Before use of CDX, NOI and NOT data were avai lable to the Regions only monthly and were not available to the public at all. The Program Office sent out a report in an Excel spreadsheet to the Regions each month. Regional and contractor personnel spent hours each week responding to requests for information from filers about the status of their NOIs based on the monthly Excel spreadsheet. With CDX in place, current data are now made availabl e immediately to Regional personnel though CDX and can be accessed by filers and the public via the NPDES Web site ( www.epa.gov/npdes/noisearch ) that is maintained by OWM separately from CDX. CDX data are automatically downloaded to the NPDES site so that current data are available to the public. Better accessibility has resulted in dramatically increased customer satisfaction. Now Regional personnel refer filers to the Web s ite where they can quickly obtain NOI status information.
Additionally, use of CDX has made historical NOI a nd NOT data readily available for the first time. Before use of CDX, data from past reports could be accessed only by looking through paper files. CDX enables access to historical data files immediately on the NPDES Web site. Since this feature has been available through CDX, the number of search requests on the e-NOI data has increased from zero to more than 2,500 requests per month.


### 8.3.4 Ancillary Benefits

Although this study focused on benefits to the Program Offices for the data flows examined, there were some benefits to other users so striking as to merit inclusion in the report. Through use of CDX for the eNOI data flow, data availability for enforcement h as risen from approximately 30 percent availability to approximately 95 percent availability. Stated anot her way, before CDX was implemented enforcementCDX Business Case Analysis

March, 2007 40 

### personnel did not have the data they needed to carry out enforcement actions an estimated 70 percent of the time. With CDX in place, enforcement personnel gene rally go into the field with the data they need. It is now the exception rather than the rule when enforcement personnel do not have needed data. 

## 8.4 Monetary Benefits of e-NOI Use of CDX

The project team identified two major areas where mone tary benefits were likely to occur due to use of CDX.

• Use of CDX eliminated the need for data entry and data format translation.

• Use of CDX avoided the cost of OWM developing its own secure, data exchange method for NOI and NOT reporting.

Exhibit 8-4 summarizes the results of the cost assessment and presents the estimated monetary benefits to the Program Office from use of CDX. As shown, th e analysis considered how three different scenarios would evolve over the course of the analysis period:

• Continuing paper submission of data,

• OWM development of an in-house system w ith equivalent functionality to CDX, and

• Use of CDX for e-NOI data submission.

Exhibit 8-4. Estimated Costs and Benefits from Implementing CDX in NOI

Year FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total
Estimated costs for paper submission

1 NOI Center costs $325,000 $325,000 $325,000 $325,00 0 $325,000 $325,000 $1,950,000

2 EPA FTE Costs $19,250 $19,250 $19,250 $19,2 50 $19,250 $19,250 $115,500

3 Total costs with paper submission $344,250 $344,250 $344,250 $344,250 $344,250 $344,250 $2,065,500

Estimated costs to develop and operate an in-house system equivalent to CDX

4 Base development costs $247,500 $247,500 $0 $0 $0 $0 $495,000

5 O&M costs $0 $49,500 $99,000 $99,000 $99,000 $99,000 $445,500

6 NOI Center costs $325,000 $300,000 $211,500 $60, 000 $60,000 $60,000 $1,016,500

7 EPA FTE costs $33,000 $33,000 $11,000 $11,0 00 $11,000 $11,000 $110,000

8 Total costs forin-house, CDXlike system $605,500 $630,000 $321,500 $170,00 0 $170,000 $170,000 $2,067,000CDX Business Case Analysis

March, 2007 41 

### Exhibit 8-4. Estimated Costs and Benefits from Implementing CDX in NOI

Year FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total
Estimated costs for implementation of CDX

9 e-NOI/CDX base development costs $238,000 $238,000 $0 $0 $0 $0 $476,000

10 e-NOI/CDX O&M costs $0 $0 $0 $0 $129,092 $120,256 $249,348

11 NOI Center costs w/e-NOI $325,000 $285,000 $211,500 $60, 000 $60,000 $60,000 $1,001,500

12 EPA FTE costs $33,000 $33,000 $11,000 $11,0 00 $11,000 $11,000 $110,000

13 Total costs forCDX implementation $596,000 $556,000 $222,500 $71,000 $200,092 $191,256 $1,836,848

Estimated monetary benefit from using CDX

14 Benefit from using electronic
vs

paper submission $251,750 4,635,00 $121,750 $273,250 $144,158 $152,994 $228,652

15 Benefit from using CDX vs developing an in-house system $9,500 $74,000 $99,000 $99, 000 -$30,092 -$21,256 $230,152



### The key source of monetary benefit for e-NOI is the re duction of contractor costs at the NOI Center. For the continued paper submission scenario, the NOI Center contractor costs would continue at a steady $325,000/year. For both the in-house, CDX-like system and the CDX scenario, the NOI Center contractor costs would decrease each year through 2006 when the e-NOI program had an opportunity to re-negotiate its contract. At that point, the e-NOI program estimated it would only require $60,000/year of support from the contractor.

Benefit Assessment . Comparing continued use of paper re porting with electronic reporting through CDX, the e-NOI program has avoided expending $228 ,652 in paper processing. Comparing the use of CDX versus developing an in-house, CDX-like system, OWM has avoided has avoided expending $230,152 on e-NOI primarily due to CDX bei ng able to leverage common infrastructure.

Return on Investment . The ROI was based on comparing use of CDX versus continued use of paper reporting. The Program Office’s investment in CDX was calculated by adding e-NOI’s estimated development costs ($476,000) and estimated O&M costs ($249,348). The estimated investment in CDX ($725,348) did not include the NOI operational pro cessing costs and EPA FTE costs that would have been incurred in the absence of developing CDX. Th e Program Office’s estimated net gain of $228,652 divided by its estimated investment of $725,348 resu lted in a 32 percent estimated ROI from using CDX rather than continuing the use of paper reporting. Had the ROI calculation been performed comparing the use of CDX to the development of an in-house, CDX-like system, the ROI also would have been estimated as 32 percent.CDX Business Case Analysis

March, 2007 42 

# 9. AQS Benefit Assessment
9.1 Program Description

The Air Quality System (AQS) is EPA’s repository of ambient air quality data. AQS is managed by the EPA Office of Air Quality and Planning Standards (OAQ PS). At the time of the study, AQS stored data from more than 10,000 air monitors, 5,000 of which were active in 2004. State, local, and tribal agencies collect the air data and submit it to AQS on a periodic basis.



## 9.2 Pre-CDX and Post-CDX Processes

Analyzing the impact of CDX on AQS was distinct from analysis of the other Program Office data flows, because before using CDX, OAQPS had just comple ted modernizing the AQS data flow. AQS had already built functionality that was similar to CDX, so CDX became an add-on to AQS, instead of being fully integrated as part of the overall modernizati on. Since the AQS data flow process had recently changed radically and was still in th e process of being finalized at the time of this analysis, no pre-CDX and post-CDX process flows were developed for AQS. 

## 9.3 Operational Benefits of Using CDX in AQS

Exhibit 9-1 summarizes the operational benefits of AQS use of CDX that were identified by the Program Office and rated according to degree of impact on da ta flow operations. The OAQPS team that worked with the project team on this analysis indicated th at their participation with CDX had been a positive experience. OAQPS expected future benefits from XM L (a widely used standard data format), data transfers, and Web services of CDX as part of the planned AQS Exchange Network data flow implementation. OAQPS also viewed use of shared OEI components such as CDX to be strategic and valuable to the Agency.

Exhibit 9-1. Summary of Operational Benefits of Using CDX for AQS Reporting

Timeliness Data Quality Accessibility

No impact Anticipated impact Anticipated impact 

# AQS No impact was anticipated or gained because AQS wasalready using a CDXlike system for reporting. The Program Office anticipates potential benefits to data quality with use of the Exchange Network. The Program Office anticipates potential benefits to data accessibility with use of the Exchange Network.



### The benefits OAQPS expected from XML data transf ers relate to the implementation of a common schema. When everyone is using a common schema, data quality increases significantly. Conceptually, if everyone is using the same definition for each data field, then stricter data validation routines and business rules can be implemented, and there will be fewer translation errors.

In general, OAQPS viewed using re-usable Web ser vices offered by CDX as a way to increase usability, system load, and, potentially, data quality at the tim e of submission. One specific Web service benefit OAQPS anticipated is increased data accessibility. O AQPS planned to make AQS data available to a much larger audience much less expensively by using CDX’s publishing Web service.CDX Business Case Analysis

March, 2007 43 

## 9.4 Monetary Benefits of Using CDX in AQS

The AQS Program is significantly different from the other data flows examined in this study. The Program Office did not adopt CDX expecting to reduce costs but rather, for the features that CDX offered beyond the modernization that OAQPS had already accomplis hed. AQS adopted CDX late in its maturity cycle; AQS had already been modernized and OAPQS had already paid for the electronic system and reaped the monetary benefits of the change from pape r to electronic reporting. Therefore, in this case, there was no basis for comparison of costs, as in the ot her data flows, with either the benefits of moving from paper to electronic submission via CDX or the avoidance of costs from using CDX rather than developing an in-house, CDX-like system.CDX Business Case Analysis

March, 2007 44 

# 10. Summary of Findings

The findings of the CDX Business Case Analysis s how that integrating CDX into EPA Program Office data flows produces monetary benefits as well as opera tional benefits in the areas of timeliness, data quality, and data accessibility. This section presents summary level findings on monetary and operational benefits for the data flows examined in this analysis. 

## 10.1 Findings on Monetary Benefits

The analysis of costs and anticipated benefits was based on data available from each Program Office at the time of the study. The data varied in type and level of detail across Program Offices. The costs are presented for three scenarios:

• Status Quo: The Program Office process prior to using CDX, generally a paper-based process. This scenario includes only O&M costs.

• Develop and implement in-house, CDX-like data exchange: Program Office development and implementation of an in-house, CDX-like data exchange system.

• Use of CDX: Program Office implementation of CDX into the data flow.
Exhibit 10-1 provides a summary of findings on moneta ry benefits to the Program Offices. The five Program Offices that adopted CDX sufficiently early in their maturity to incur monetary benefits from use of CDX are shown in the exhibit. A dash appears wh ere data were not available. Estimated monetary benefits are shown, when available, for the difference between paper submission and electronic submission through CDX and/or the difference betwee n using CDX and developing an equivalent inhouse system.
The purpose of presenting the monetary benefit inform ation is to demonstrate a trend of monetary benefits from using CDX. Note that costs and benef it data are not comparable across data flows due to differences among data flows in the components of C DX used, the nature of the status quo system, the number of users, when in the system maturity CDX was adopted, and other factors.

Exhibit 10-1. Summary of Estimated 

### Benefits of Using CDX in EPA Program Data Flows Estimated Monetary Benefits

Program Data Flow Use of paper vs electronic submission through CDX Use of CDX vs in-house, CDX-like system 

### SDWIS



### – $765,600



### Lead-based Paint Abatement $9,500,000 Based on projected increase in submissions starting in 2010 and assumption of 75% use of CDX 

### –

UCMR



### – $91,150



### TRI $1,036,504 $1,481,102



### e-NOI $228,652 $230,152CDX Business Case Analysis

March, 2007 45 

### As shown in Exhibit 10-1, although data for all cost el ements and scenarios were not available for all data flows, sufficient data existed to identify distinct mone tary benefits for five of the six programs included in the analysis. The following primary monetary benefit findings were ma de based on study data:

• By using CDX Program Offices in this study av oided incurring between an estimated $90,000 and $1,400,000 in infrastructure development costs to attain a secure data exchange mechanism.

• All Program Offices (except AQS, which had alr eady modernized) estimated cost reductions by avoiding data entry and data format translation through use of CDX.

• Using CDX reduced Program Office estimated annual O&M costs.

• Program Office data collection costs were re duced by an amount between $.71 and $38 per submission in the three Program Offices that collected per-submission data. Three of the Program Offices provided information on data collection costs per-submission before and after CDX use. Per-submission costs for the three Programs for which these data were available are shown in Exhibit 10-2.

Exhibit 10-2. Summary of Per-Submission Estimated Costs and Benefits

Program Data Flows 

### Lead-based Paint Abatement TRI e-NOI

Per-submission cost prior to use of CDX $5.08 for notifications; $38.15 for certification applications $24.79 for paper; $1.46 for diskette $21.81

Per-submission cost after use of CDX $0.00 $0.75 $19.76

Estimated Per-Submission Monetary Benefit $5.08 for notifications; $38.15 for certification applications $24.04 for paper; $0.71 for diskette $2.05



### The project team worked with the program data flow managers to determine the most sensible way to calculate each Program Office’s return on investment from using CDX. The most conservative approach was taken in each case to avoid overestimating ROI. Estimated ROIs for the four Program Offices for which ROIs were calculated are shown in Exhibit 10 -3. ROI was calculated according to a standard formula – net benefit divided by the cost of investment.

Exhibit 10-3. ROI Summary

Program Data Flows

ROI Basis 

### SDWIS UCMR TRI e-NOI

Comparison of use of CDX to use of paper process 

### √ √

Comparison of use of CDX to development of in-house, CDX-like system 

### √ √

Estimated Return on Investment 119% 5% 271% 32%CDX Business Case Analysis

March, 2007 46 

### As shown in Exhibits 10-1 through 10-3, the value of the monetary benefits and ROI varied significantly among program data flows. This variance w as due to a number of factors including:

• volume and frequency of data submission and processing,

• length of the time period selected for the analysis,

• how the Program Office captured costs,

• available cost information,

• the features of CDX that the Program adopted,

• when in the life cycle of the data flow CDX was adopted, and

• number of respondents using the data flow. 

## 10.2 Findings on Operational Benefits

All Program Offices experienced or anticipated ope rational improvements in timeliness, data quality, and/or accessibility as a result of CDX use. Operati onal benefits of implementing CDX in each Program Office were provided in Sections 4 – 9. Exhibit 10- 4, which appears on the following page, combines the operational benefits findings to illustrate the commonalit y of benefits across data flows. Four of the six Program Offices gained benefits from using CDX in the areas of timeliness, data quality, and accessibility. One Program Office had experienced be nefits in timeliness and data quality, but there was not yet sufficient program use to determine whether accessibility was impacted by using CDX. The sixth Program Office anticipated benefits in data quality a nd accessibility, but did not c onclude that it benefited from CDX in timeliness since that Program Office ha d already modernized before adopting CDX.
The primary study finding on operational benefits of CDX use is that converting from a paper-based system to CDX (or another electronic reporting system equivalent to CDX), genera lly results in benefits in timeliness, data quality, and accessibility. Prior to CDX most data flows received information in the form of paper, diskettes, or e-mails. This meant that Program Offices had to spend considerable resources in translating these data sources into a single format . CDX has provided a single format for reporting, which has improved data timelines s, quality, and accessibility. As with the monetary benefits, the significance of the operational benefits is affected by how mature the data flow was when CDX was adopted, how many CDX features the data flow used , and how many respondents use the program flow via CDX.CDX Business Case Analysis

March, 2007 47 

### Exhibit 10-4. Summary Findings on Operational Benefits of Using CDX

Program Data Flow Timeliness Data Quality Accessibility

Positive Impact Positive Impact Positive Impact 

### SDWIS Data errors can be detected and responded to by Primacy Agencies within minutes or hours. Prior to use of CDX, data review required weeks or months of manual effort. The process flow using CDX supports better and timelier QA review of data. CDX enabled SDWIS to eliminate a complex, time-consuming mainframe interface to access data. Data are now accessed easily, which streamlines the cost of responding to data requests. Positive impact Positive impact No Impact

### Leadbased PaintAbatement Prior to use of CDX, form processing required an average of 10 days. Forms are now entered by the applicants directly into the system on the Web, reducing processing time to an average of 2 days. Forms submitted by fax or mail were often either illegible or incomplete, delaying data entry. With CDX, data are quality checked at the time of entry, increasing accuracy and reducing the need for corrections. There was insufficient program use at the time of analysis to identify accessibility benefits.

Exceptionally Positive Impact Exceptionally Positive Impact Exceptionally Positive Impact 

### UCMR Use of CDX reduced data preparation time from 5-7 years to 90-120 days. CDX resolved data completeness and quality issues. CDX offers a secure, integrated repository for states, labs, PWSs, and EPA.

Exceptionally Positive Impact Exceptionally Positive Impact Positive impact 

### TRI • With use of CDX, public data release is possible 7-8 months earlier than previously.



### • Data processing time was reduced from 35 minutes (for paper submission) or 8 minutes (for diskette submission) to 4 minutes using CDX. Error rates prior to using CDX were 10.4% for paper processing and 2.1% for diskette processing. Use of CDX reduced the error rate to 0.6%. With the implementation of CDX in the TRI data flow, states are able to generate reports and can view, review, and validate data earlier in the process.

Exceptionally positive impact Exceptionally positive impact Exceptionally positive impact 

### e-NOI Use of CDX has eliminated approximately 33 days of processing time to obtain a permit. Administrative error rates reduced from 80% to near 0%. Current and historical data are readily available to the Regions and public for the first time, via CDX download to the NPDES Web site.
No impact Anticipated impact Anticipated impact 

### AQS No impact was anticipated or gained because AQS was already using a CDX-like system for reporting. The Program Office anticipates benefits to data quality with use of the Exchange Network. The Program Office anticipates benefits to data accessibility with use of the Exchange Network.CDX Business Case Analysis

March, 2007 48 

### Although this analysis focused primarily on benefits to the Program Offices, interviews uncovered some benefits to other users so striking as to merit inclusi on in the report. These ancillary benefits are iterated below:

• Some drinking water laboratories reported as much as a 90 percent reduction in data entry time after UCMR began using CDX.

• The integration of CDX with Pay.Gov enables compan ies applying for lead abatement certifications to pay their certification fees directly from CDX. This is not a direct CDX benefit since CDX merely takes the users to the Pay.Gov site, but it results in a notable benefit to users.

• Industry reported a 2-hour time savings from the elect ronic signature feature available in TRI through CDX. Considered in the context of an estimated 25,000 facilities who submit TR I data, this benefit is substantial.

• Data availability in e-NOI to support enforcem ent actions rose from 30 percent availability to 95 percent availability with the adoption of CDX.

Anecdotal evidence of such benefits to EPA enforcem ent, state, reporting entities, and the public warrants further examination to acquire data that documents benefits of CDX to users other than Program Offices.
The project team did not collect data on risk reducti on; however, the operational benefits findings lead to the observation that use of CDX appears to reduce risk s associated with exchange of environmental data, in line with the CDX objectives described in section 2. 1. CDX has provided a secure method to transfer information. This feature has resulted in major be nefits for several Program Offices and EPA as a whole, and has contributed to homeland security. For exam ple, secure data transmission of the location of hazardous chemicals (TRI) and water supplies (SDW IS) means that CDX has decreased the possibility that this information may fall into the wrong hands. Th is topic merits further examination to acquire data that substantiates the role of CDX in reducing ri sks associated with environmental data exchange.CDX Business Case Analysis

01-23-07 A-1 

# APPENDIX A
DETAILED TABLES OF TRI ESTIMATED COSTSCDX Business Case Analysis

01-23-07 A-2 

### This appendix contains a series of six tables that pr ovide further detail and background data used in the TRI benefit analysis (presented in Section 7). FY2002 costs represent actual TRI program costs; costs for FY2003 – 2008 were estimated based on Program Offi ce projections at the time the analysis was performed.
The Program Office estimated the cost of continuing to use paper and diskette reporting over the analysis period. These costs are shown in Table A-1.

Table A-1. Estimated Costs for Use of Paper and Diskette for TRI Reporting

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Paper 22% 22% 21% 21% 20% 20% 19%
Disk 78% 78% 79% 79% 80% 80% 81%
Total 100% 100% 100% 100% 100% 100% 100%
Number of Forms Paper 26,001 23,634 21,000 21,000 20,000 20,000 19,000 Disk 92,187 83,792 79,000 79, 000 80,000 80,000 81,000 Total 118,188 107,425 100,000 100,000 100,000 100,000 100,000
Dollar Cost Per Form Paper $24.79 $24.79 $24.79 $24.79 $24.79 $24.79 $24.79 Disk $1.46 $1.46 $1.46 $1.46 $1.46 $1.46 $1.46
Total Cost Paper $644,574 $585,874 $520,590 $52 0,590 $495,800 $495,800 $471,010 Disk $134,592 $122,336 $115,340 $11 5,340 $116,800 $116,800 $118,260 Total $779,166 $708,210 $635,930 $63 5,930 $612,600 $612,600 $589,270



### The Program Office estimated the cost of following up with facilities to collect missing signatures. Table A-2 shows the estimated number of forms with missi ng signatures and the estimated cost to follow up and obtain the necessary signatures.

Table A-2. Estimated Number of TRI Reports with Missing Signatures and Cost to Follow Up

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008
Paper Reports
Total number of reports 26,001 23,634 21,000 21,00 0 20,000 20,000 19,000
Percent of reports w/missing signatures 0.8% 0.9% 1.0% 0.9% 1.0% 0.9% 1.0%

Total number of reports w/ missing signatures 208 208 208 198 198 188 188

Cost of responding to a missing signature $30.46 $30.46 $30.46 $30. 46 $30.46 $30.46 $30.46

Annual cost to respond to missing signatures $6,336 $6,336 $6,336 $6, 034 $6,034 $5,732 $5,732CDX Business Case Analysis

01-23-07 A-3 Table A-2. Estimated Number of TRI Reports with Missing Signatures and Cost to Follow Up

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008

Diskettes Total number of reports 92,187 83,792 79,000 79,00 0 80,000 80,000 81,000
Percent of reports w/missing Signatures 0.3% 0.3% 0.3% 0.3% 0.3% 0.3% 0.3%

Total number of reports with missing signatures 238 238 238 241 241 244 244

Cost of responding to a missing signature $21.25 $21.25 $21.25 $21. 25 $21.25 $21.25 $21.25

Annual cost to respond to missing signatures $5,058 $5,058 $5,058 $5, 122 $5,122 $5,186 $5,186

Total paper and diskette cost to respond to missing signatures $11,394 $11,394 $11,394 $11,1 56 $11,156 $10,918 $10,918



### Working with TRI program staff, the project team estimated the costs for using an electronic reporting system (either CDX or an in-house, CDX-like system . Table A-3 shows the estimated costs of using electronic reporting (either CDX or an in-house, CDX-like system), assuming that the percentage of submissions via paper or diskette will decrease over tim e. TRI program staff projected data entry costs based on FY2002 costs to enter data. Table A-3 costs include contractor costs and the EPA FTE costs to develop and maintain the electronic system. Specifica lly, the data entry cost for a paper submission was estimated at $24.79/form, for diskette was $1.46/form, and for CDX electronic reporting through CDX or an in-house, CDX-like system was $0.75/form.

Table A-3. Estimated Costs of Paper, Disket te, and CDX or In-House, CDX-like System

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Paper 19% 18% 14% 10% 9% 8% 5%
Diskette 74% 59% 50% 39% 35% 27% 15% CDX or in-house, CDX-like system 7% 23% 36% 51% 56% 65% 80%

Total 100% 100% 100% 100% 100% 100% 100%
Number of Forms Paper 22,456 19,337 15,000 15,000 15, 000 10,000 5,000
Diskette 87,459 63,381 55,000 50,000 45,00 0 25,000 15,000 CDX or in-house, CDX-like system 8,273 24,708 30,000 35,000 40,00 0 65,000 80,000

Total 118,188 107,425 100,000 100,000 100,000 100,000 100,000
Dollar Cost Per Form Paper $24.79 $24.79 $24.79 $24.79 $24.79 $24.79 $24.79 Diskette $1.46 $1.46 $1. 46 $1.46 $1.46 $1.46 $1.46 CDX or in-house, CDX-like system $0.75 $0.75 $0.75 $0. 75 $0.75 $0.75 $0.75CDX Business Case Analysis

01-23-07 A-4 Table A-3. Estimated Costs of Paper, Disket te, and CDX or In-House, CDX-like System

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total Cost Paper $556,677 $479,352 $371,850 $371,850 $371, 850 $247,900 $123,950 Diskette $127,690 $92,536 $80,300 $73,000 $65,7 00 $36,500 $21,900
CDX or in-house, CDX-like system $6,205 $18,531 $22,500 $26,250 $30,0 00 $48,750 $60,000

Total $690,572 $590,419 $474,650 $471,100 $467, 550 $333,150 $205,850



### Actual development costs and estimated operational co sts were used for FY2002 data submission through TRI using CDX. Table A-4 shows these costs and the pr ojected costs to enter data from paper, diskette, and CDX over the study period. EPA FTE costs to de velop and maintain the system also are included.

Table A-4. Estimated Costs to Develop and Implement TRI through CDX

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total
O&M $0 $0 $14,570 $24,105 $38,284 $138, 642 $122,637 $338,238 Paper $556,677 $479,352 $371,850 $371,850 $371,850 $24 7,900 $123,950 $2,523,429 Diskette $127,690 $92,536 $80,300 $73,000 $65,700 $36, 500 $21,900 $497,626 CDX $6,205 $18,531 $22,500 $26,250 $30,000 $48, 750 $60,000 $212,236

EPA FTE costs $55,000 $11,000 $11,000 $11,000 $11,000 $11, 000 $11,000 $121,000

Total costs w/CDX $745,572 $601,419 $459,762 $366,599 $353,387 $43 6,132 $339,487 $3,692,529



### TRI program staff and CDX software engineers work ed to develop a cost estimate for developing and operating an in-house system equivalent to CDX. Table A-5 shows these estimated costs.

Table A-5. Estimated Cost to Develop and Im plement an In-House, CDX-like System for TRI

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total Development $247,500 $247,500 $0 $487,400 $0 $0 $0 $982,400 O&M $0 $49,500 $99,000 $99,000 $196, 480 $196,480 $196,480 $836,940 Paper $556,677 $479,352 $371,850 $371,850 $371,850 $24 7,900 $123,950 $2,523,429 Diskette $127,690 $92,536 $80,300 $73,000 $65,700 $36, 500 $21,900 $497,626
Submissions via in-house system $6,205 $18,531 $22,500 $26,250 $30, 000 $48,750 $60,000 $212,236

EPA FTE costs $55,000 $11,000 $11,000 $11,000 $11, 000 $11,000 $11,000 $121,000

Total cost for in-house system $993,072 $898,419 $545,371 $935,542 $52 3,690 $493,970 $41 3,330 $5,173,631CDX Business Case Analysis

01-23-07 A-5 

### All of the scenarios in Tables A-1 through A-5 were combined to estimate the Program Office’s overall cost avoidance from using CDX (see Table A-6). As shown, there is substantial anticipated cost avoidance from using CDX. Specifically, over the study period (FY2002 – FY2008), the TRI program would avoid expending more than $1 million in data processing of paper and diskette by implementing CDX and would avoid expending $1.4 million by implem enting CDX rather than developing an in-house system equivalent to CDX.

Table A-6. Summary Cost Avoidance from TRI Use of CDX

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total TRI using paper and diskette submission Paper $644,574 $585,874 $52 0,590 $520,590 $495,800 $49 5,800 $471,010 $3,734,238 Paper missing signatures $6,336 $6,336 $6,336 $6,034 $6,034 $5,732 $5,732 $42,540
Diskette $134,592 $122,336 $115,340 $115, 340 $116,800 $116,800 $118,260 $839,468 Diskettes missing signatures $5,058 $5,058 $5,058 $5,122 $5,122 $5,186 $5,186 $35,787

EPA FTE costs $11,000 $11,000 $11,000 $11,000 $11,000 $11,0 00 $11,000 $77,000
Total TRI w/paper and diskette submission $801,559 $730,603 $658,323 $658,085 $63 4,755 $634,518 $61 1,188 $4,729,032

TRI using in-house CDX-like system Development $247,500 $247,50 0 $0 $487,400 $0 $0 $0 $982,400 O&M $0 $49,500 $99,000 $99,000 $196, 480 $196,480 $196,480 $836,940 Paper $556,677 $479,352 $371,850 $371,850 $371,850 $24 7,900 $123,950 $2,523,429 Diskette $127,690 $92,536 $80,300 $73,000 $65,700 $36, 500 $21,900 $497,626
Submissions via CDX-like system $6,205 $18,531 $22,500 $26,250 $30,000 $48, 750 $60,000 $212,236
EPA FTE costs $55,000 $11,000 $11,000 $11, 000 $11,000 $11,000 $11,000 $121,000
Total TRI w/inhouse, CDX-like system $993,072 $898,419 $545,371 $935,542 $52 3,690 $493,970 $41 3,330 $5,173,631

TRI using CDX O&M $0 $0 $14,570 $24,105 $38,284 $138, 642 $122,637 $338,238 Paper $556,677 $479,352 $371,850 $371,850 $371,850 $24 7,900 $123,950 $2,523,429 Diskette $127,690 $92,536 $80,300 $73,000 $65,700 $36, 500 $21,900 $497,626 CDX $6,205 $18,531 $22,500 $26,250 $30,000 $48, 750 $60,000 $212,236 EPA FTE costs $55,000 $11,000 $11,000 $11, 000 $11,000 $11,000 $11,000 $121,000 Total TRI w/CDX $745,572 $601,419 $459,762 $36 6,599 $353,387 $436,13 2 $339,487 $3,692,529CDX Business Case Analysis

01-23-07 A-6 Table A-6. Summary Cost Avoidance from TRI Use of CDX

FY2002 FY2003 FY2004 FY2005 FY2006 FY2007 FY2008 Total Summary Estimated Cost Avoidance Cost savings TRI w/CDX vs TRI w/paper and diskette submission $55,987 $129,185 $158,104 $151,880 $117, 921 $151,726 $271,700 $1,036,504

Cost savings TRI w/CDX vs TRIw/in-house, CDXlike system $247,500 $297,000 $84,431 $562,295 $158, 196 $57,838 $73,843 $1,481,102

Estimated Costs per Submission Average Cost/ Submission
TRI w/o electronic submission $6.78 $6.80 $6.58 $6. 58 $6.35 $6.35 $6.11 $6.52

TRI w/in-house, CDX-like system $8.40 $8.36 $5.85 $10.69 $6.75 $5.41 $4.13 $7.13

TRI w/CDX $6.31 $5.60 $5. 00 $5.06 $5.17 $4.83 $3.39 $5.09