A Business Case Analysis of EPA’s 

Central Data Exchange 

March, 2007 
 CDX 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 Number GS00T99ALD0203, Task Order number T038. 
 CDX Business Case Analysis 

 

March, 2007 ii 

Table of Contents 

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

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

2.1 BACKGROUND.............................................................................................................................. 3

2.2 PURPOSE AND SCOPE.................................................................................................................... 4

2.3 ASSUMPTIONS AND LIMITATIONS................................................................................................. 5

2.4 SELECTION OF DATA FLOWS ........................................................................................................ 6

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

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

4.1 PROGRAM DESCRIPTION............................................................................................................. 13

4.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 13

4.3 OPERATIONAL BENEFITS OF SDWIS USE OF CDX .................................................................... 15

4.3.1 Timeliness............................................................................................................................. 16

4.3.2 Data Quality ......................................................................................................................... 16

4.3.3 Accessibility.......................................................................................................................... 16

4.4 MONETARY BENEFITS OF SDWIS USE OF CDX......................................................................... 16

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

5.1 PROGRAM DESCRIPTION............................................................................................................. 18

5.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 18

5.3 OPERATIONAL BENEFITS OF LEAD-BASED PAINT ABATEMENT PROGRAM USE OF CDX............ 20

5.3.1 Timeliness............................................................................................................................. 20

5.3.2 Data Quality ......................................................................................................................... 21

5.3.3 Accessibility.......................................................................................................................... 21

5.3.4 Ancillary Benefit................................................................................................................... 21

5.4 MONETARY BENEFITS OF LEAD-BASED PAINT ABATEMENT PROGRAM USE OF CDX................ 21

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

6.1 PROGRAM DESCRIPTION............................................................................................................. 24

6.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 24

6.3 OPERATIONAL BENEFITS OF UCMR USE OF CDX ..................................................................... 26

6.3.1 Timeliness............................................................................................................................. 26

6.3.2 Data Quality ......................................................................................................................... 27

6.3.3 Accessibility.......................................................................................................................... 27

6.3.4 Ancillary Benefit................................................................................................................... 27

6.4 MONETARY BENEFITS OF UCMR USE OF CDX ......................................................................... 27

7. TRI BENEFIT ASSESSMENT........................................................................................................ 30

7.1 PROGRAM DESCRIPTION............................................................................................................. 30

7.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 30

7.3 OPERATIONAL BENEFITS OF TRI USE OF CDX .......................................................................... 32

7.3.1 Timeliness............................................................................................................................. 33

7.3.2 Data Quality ......................................................................................................................... 33

7.3.3 Accessibility.......................................................................................................................... 33

7.3.4 Ancillary Benefits ................................................................................................................. 33

7.4 MONETARY BENEFITS OF TRI USE OF CDX ............................................................................... 34
 CDX Business Case Analysis 

 

March, 2007 iii 

8. E-NOI BENEFIT ASSESSMENT ................................................................................................... 37

8.1 PROGRAM DESCRIPTION............................................................................................................. 37

8.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 37

8.3 OPERATIONAL BENEFITS OF E-NOI USE OF CDX ...................................................................... 38

8.3.1 Timeliness............................................................................................................................. 39

8.3.2 Data Quality ......................................................................................................................... 39

8.3.3 Accessibility.......................................................................................................................... 39

8.3.4 Ancillary Benefits ................................................................................................................. 39

8.4 MONETARY BENEFITS OF E-NOI USE OF CDX........................................................................... 40

9. AQS BENEFIT ASSESSMENT ...................................................................................................... 42

9.1 PROGRAM DESCRIPTION............................................................................................................. 42

9.2 PRE-CDX AND POST-CDX PROCESSES...................................................................................... 42

9.3 OPERATIONAL BENEFITS OF USING CDX IN AQS...................................................................... 42

9.4 MONETARY BENEFITS OF USING CDX IN AQS.......................................................................... 43

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

10.1 FINDINGS ON MONETARY BENEFITS .......................................................................................... 44

10.2 FINDINGS ON OPERATIONAL BENEFITS ...................................................................................... 46
 CDX Business Case Analysis 

 

March, 2007 1 

1. EXECUTIVE SUMMARY 

In 2000, EPA’s Office of Environmental Information (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 enabling the Agency as a whole to garner efficiencies 

by consolidating data exchange activities around a robust 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 Inventory 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; Water; Prevention, Pesticides and Toxic Substances; and 

Environmental Information. The six program data exchanges, 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 other 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 Program 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 the baseline scenario to be 

used and collaborated on the overall calculation of the 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 results were presented to and approved by Program 

Office management and OEI before this report was prepared. The results presented offer a snapshot in 

time of estimated benefits that the six Program Office data flows garnered from CDX. Because the 

benefit assessments were intentionally conservative, current or actual benefits are likely greater than those 

projected in the estimates. 

Summary benefits are captured in the tables on the next page and should underscore the narrow scope of 

this study, which captures and monetizes only a part 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 expenses 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 

 

March, 2007 2 

benefit that CDX might provide through enhanced data security, or by enabling the consolidation of 

multiple manual and electronic program data collection systems across the Agency into one. 

Nevertheless, this study clearly demonstrates CDX’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 submissions handled by CDX; and numerous other factors. 

Monetary benefits are therefore not strictly comparable 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 connection 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 time. 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 

 

March, 2007 3 

2. INTRODUCTION 

2.1 Background 

In 2000, EPA’s Office of Environmental Information 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 services 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

UCMR AQS

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 CDX 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 bridge 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 

 

March, 2007 4 

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

stakeholders. 

• Validate quality of environmental data through automated compliance checks with agreed upon data 

standards and business rule validation checks on exchanged data. 

CDX is intended to eliminate or reduce risk associated 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 infrastructure 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 benefit 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 validation checks on submitted data. 

• Data exchange between different system platforms, 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 Information (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 impact of CDX use on representative data flow processes 

and determine the monetary and operational benefits of CDX use to the 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 estimate 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, industry, or OEI benefits or costs were incorporated; and the 

analysis did not consider potential benefits to human health or the environment that may result from 

increased data timeliness, quality, and accessibility. Meanwhile, the Environmental Council of the States 

(ECOS) recently completed an in-depth analysis of state benefits from use of the Exchange Network. 
 CDX Business Case Analysis 

 

March, 2007 5 

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 operational benefits examined included improvements in 

timeliness, data quality, and data accessibility. Although improved operational efficiencies result in cost 

savings, OEI did not assign a monetary value to the operational 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 analysis 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. Stakeholders are encouraged to use the data presented 

in this report to consider potential benefits CDX could 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 that 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 approach for participating Program Offices. Because 

the CDX cost share had not been determined at the time 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 varied significantly across data flows. Additionally, 

some historical information was not available. These 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 there 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 approach to reflect the particular data flow factors. 

Because operational improvements were not quantified in monetary terms, the estimated monetary 

benefits are conservative. The actual monetary benefits are likely higher than those reported in most 

cases. 
 CDX Business Case Analysis 

 

March, 2007 6 

2.4 Selection of Data Flows 

EPA sought to select a representative sampling of Program Office data flows for participation in the 

business case analysis. Four primary criteria were used for selection: 

1) Availability of program resources to work with 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 flows; 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 analysis, identifies the EPA Program Offices responsible 

for each data flow, provides a brief overview of the data 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 activities (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 

 

March, 2007 7 

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 

 

March, 2007 8 

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. This section describes each of the steps shown in the 

exhibit. This approach was applied to all six Program 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 project 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 services 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 summaries 
 CDX Business Case Analysis 

 

March, 2007 9 

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 maintain? 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 synchronized 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 managers 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 period 
 CDX Business Case Analysis 

 

March, 2007 10 

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 flow managers to develop process maps (i.e., flow 

diagrams) of the data flow process prior to using CDX 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 and 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 development 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 implemented. For baseline scenario 2, the project team 

worked with the TRI program data flow2

 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 chosen 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 operation. 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 and fax), diskette, and other forms of data input used 

prior to implementing CDX. 

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

• O&M costs for existing systems supporting the data exchange function. 

Baseline Scenario 2 – In-house, CDX-like System Cost Elements 

• Program Office staff time to oversee system development and implementation. 

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

• O&M costs to maintain the system. 

CDX Use Cost Elements 

• Contractor resources to integrate the CDX application into existing program systems. 

• Program Office staff time required to support design, development, and integration 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 accepted 

this estimate as reasonable.
 CDX Business Case Analysis 

 

March, 2007 11 

• 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 data 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 Program Offices in this study to ensure that cost 

avoidance was not overestimated in the event that cost-sharing is implemented in future years. O&M 

costs were based on Office of Information Collection (OIC) estimates or, if this was unavailable, an 

industry standard of approximately 20 percent per year of total development and implementation costs. 

This translated into an imputed O&M cost of approximately $100,000 per year for most data flows. 

O&M costs for individual data flows are included in the data flow discussions in Sections 4 - 9 of this 

report. 

For the first four data flows analyzed, the project team 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 (LOE) estimates. This reflects the average dollar cost 

of program full-time equivalents (FTEs) in 2005 as documented 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 identifying operational benefits by comparing the 

processes before and after CDX in three areas: timeliness, data quality, and data accessibility. Although 

there is certain to be cost savings associated with these benefits, an acceptable method to quantify the 

benefits was not available; thus these savings are not included in the analysis. 

Timeliness: In evaluating changes in timeliness, the project team looked at how using CDX has affected 

the time it takes for information to be submitted and rendered 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 turnaround 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 project team looked at how using CDX has affected 

the value, integrity, and overall quality of the data processed 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 Program 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 appropriate 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 management 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 project 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 management briefings and prepared final benefits 

report summaries for each data flow. These benefit 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 compliance and enforcement information to EPA for 

inclusion in the Safe Drinking Water Information System (SDWIS), as required by the Safe Drinking 

Water Act (SDWA) Amendments of 1996. The Office of Ground Water and Drinking Water 

(OGWDW), which is responsible for SDWIS, receives, 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 reporting process prior to the use of CDX. The Primacy 

Agency responsible for the facility received the data 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 Agency to resolve any problems, and submitted reviewed data to EPA 

HQ via mail, fax, or e-mail on paper, data file, diskette, 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 process 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 

No 
 CDX 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 Agencies and EPA. Under the new process, completed in 

2005, Primacy Agencies enter data directly in SDWIS/Federal and SDWIS/State and the data are 

transferred via CDX to EPA HQ. The data are automatically 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 degree 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 to 

eliminate 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 CDX
 CDX 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 entered with errors. The program data flow manager reported that after 

CDX was implemented, the elapsed time between data 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 sent 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 review processes. After CDX was implemented, the need for multiple 

data entry and data translation processes was eliminated. Data were entered in a single form and sent 

directly to EPA HQ. EPA HQ and Primacy Agencies no longer had to spend resources managing and 

translating data and could instead concentrate resources on improving the quality of data. The program 

data flow manager reported that using CDX resulted in better quality initial 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 considerable 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 developing and testing, and 5 years (FY2006 – FY2010) for 

operation. Based on the review of the processes prior to and after use of CDX, the project team 

anticipated that OGWDW monetary benefits would occur through use of CDX rather than developing its 

own in-house, CDX-like secure data exchange mechanism. Use of either of these options would 

eliminate the need for data entry 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 process even if CDX had not existed, the baseline 

used for comparison was OGWDW’s development 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, development, testing and implementation (includes process 

reengineering and training) of secure Web infrastructure for data exchanges between EPA and 

Primacy Agencies. 

• $420,000 estimated spending on design, development, 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 than 

Developing 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-like system (Row 1) was estimated at $150,000 per year for 5 years, 

resulting in an estimated total of $750,000 for O&M. The O&M estimate includes operation and 

maintenance of the system and expansion of infrastructure functionality as federal security requirements 

expanded. 

The total estimated cost of $315,000 for implementing SDWIS through CDX (Row 2) over a period of 3 

years included: 

• $247,000 estimated spending on design, development, 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 avoided 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 percent 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 (OPPT) 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 abatement 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 apply to EPA for company certification and provide 

advance notice of future abatement actions. Training 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 abatement, and payment of certification fees through 

Pay.Gov. 

2) Notifications of forthcoming abatement actions, upcoming training classes, and attendance at training 

sessions. 

Prior to use of CDX, both processes involved submission 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 obtained the relevant form from the EPA lead abatement 

Web site or another source such as EPA or state offices, completed the form, and sent the form to EPA 

either via facsimile or by mail. The hard copy form was received at EPA and forwarded to a data entry 

contractor. The contractor then reviewed the file and entered the data in the 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 entered 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 problems 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 electronic reporting system for lead abatement notification 

and certification through CDX. Exhibit 5-2 shows the process after CDX was implemented. 

Companies were required initially to register and obtain a CDX ID; the process of obtaining a CDX ID 

was later changed to open registration as a streamlining measure. With CDX in place, companies go online and enter data into the appropriate form electronically through CDX. The CDX Web page has 

numerous automatic error checks and prevents companies from sending incomplete or inaccurate data. 

After the form is completed, it is automatically 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 

(daily)

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

No
 CDX 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-based 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 analysis was performed, CDX had recently been integrated 

into the lead-based paint abatement system and fewer 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 

Paint 

Abatement

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 contractors 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 completed 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 CDX 
 CDX Business Case Analysis 

 

March, 2007 21 

After CDX was implemented, forms are now completed 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 result, data that contained undetected errors was entered into the system. 

With CDX in place, submitters enter data into an electronic form on the Web. The form is automatically 

error checked at the time of data entry, and the submitters 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 payment 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 directly 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-based Paint Abatement Program Use of 

CDX 

The timeframe considered for the lead-based paint 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 scenario here because it was immediately recognized by 

all as more costly than the CDX alternative. Therefore, 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 entry, 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 associated 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-related maintenance including review of system data, 

meetings with OEI staff to discuss general CDX issues, 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 approximately $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 through 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 preliminary at that time to calculate a meaningful 

return on investment. 

The Program Office anticipates that the most significant 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 substantial 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 during FY2010 – FY2013. As shown in the exhibit, 

the increase in submissions would be expected to be the highest in FY2011, falling somewhat in FY2012 
 CDX 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 CDX3

. 

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 will 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 Internet. For the purposes of this report, the 

Program Office felt an assumption that 75% of all respondents will 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 9,200 
 CDX Business Case Analysis 

 

March, 2007 24 

6. UCMR Benefit Assessment 

6.1 Program Description 

The Unregulated Contaminant Monitoring Rule (UCMR) is the regulatory mechanism used to describe 

procedures to report, evaluate, and prioritize contaminants 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 standards are based on sound science. Every 5 years, 

public water systems (PWSs) submit data 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 converted from its native form into a common electronic form. Each data 

form that was submitted required EPA to construct a data converter to convert 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 until data from all public water suppliers were acquired. This slowed 

the data conversion process. After the data had been 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 reporting 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 the 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 automated routines. Errors are resolved via on-line 

communication with the public water suppliers who submitted the data. When errors are found, the data 

are sent back to the PWS with notes identifying the errors. 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

Send to PWS to Problems?

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 iterations
 CDX 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 degree 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 UCMR Impact

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 EPA 
 CDX Business Case Analysis 

 

March, 2007 27 

6.3.2 Data Quality 

UCMR data quality has improved dramatically 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 was 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 concerning enforcement and regulation. In addition, 

CDX offers an automated audit trail of receipt, modifications, and approvals; automated authentication 

and access controls with logging; and real-time e-mail notifications of exceptions. 

6.3.3 Accessibility 

As a result of the dramatic improvements in timeliness, CDX was able to substantially improve 

accessibility to the UCMR data. Prior to CDX implementation, 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 public 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 developing 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 potential 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 forms and business rules. 

UCMR was one of the first programs to adopt CDX, therefore, UCMR’s CDX development costs 

included a significant amount of research and development (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 development 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 system 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 included in the analysis. As shown in Row 5, most 

of the estimated $601,850 O&M costs are projected to occur in the 4th collection period. 

Benefit Assessment. The primary monetary benefit gained from 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, the 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 benefit is more representative of what these programs 

could anticipate. 

Return on Investment. In terms of the ROI, OGWDW’s estimated 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 data 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 covered 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 order to help communities prepare to respond to chemical 

spills and similar emergencies. EPCRA Section 313 requires 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 paper or diskette. Exhibit 7-1 illustrates the TRI 

data flow process prior to use of CDX. As shown, facilities prepared paper or diskette versions of their 

reports. Diskette versions were prepared using TRI-ME software. Facilities 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 communication 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. Exhibit 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 

TRIS 
 CDX 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 Benefits 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 enters 

data in TRIME

TRIS 

QA Data and 

Review Correct Data 

Problems? 

Yes 

Finalize and 

publish data 

No 

CDX 

States view, 

review, and 

validate data 
 CDX 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 TRI public data release (PDR), which contains the 

official government figures on toxic releases. PDR is used 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 paper and diskette. With CDX’s eSignature feature, 

forms cannot be submitted without signatures, resulting 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 reports 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 without 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 signature feature. Considered in the context of 

saving 2 hours of staff time for each of the estimated 25,000 facilities who submit TRI 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 industry and states time and money. 

Industry reduces its reporting burden because it no longer sends duplicate reports to the states. And states trim the money and 

time they spend collecting and maintaining their own TRI data because 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 CDX 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 assessment 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 with 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 $495,800 $495,800 $471,010 $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 $371,850 $247,900 $123,950 $2,523,429 

9 Diskette 

submissions $127,690 $92,536 $80,300 $73,000 $65,700 $36,500 $21,900 $497,626 
 CDX 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 $38,284 $138,642 $122,637 $338,238 

14 Paper 

submissions $556,677 $479,352 $371,850 $371,850 $371,850 $247,900 $123,950 $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 $151,880 $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 enter data at the time of the analysis. Costs included 

contractor costs and the EPA FTE costs to develop and maintain the data entry system. Tables showing 

detailed cost breakdowns for TRI cost estimates 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 diskette. Comparing the use of CDX versus developing 

an in-house, CDX-like system, OIAA has avoided expending 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 expending $24.04 in processing costs for each paper 

submission and $.71 in processing costs 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 calculated as $382,238 by adding the total estimated 

O&M costs shown in Row 13 ($338,238) and the additional portion of estimated EPA FTE costs incurred 

because of the need to supervise CDX development in FY2002 extrapolated from Row 17 ($55,000 - 

$11,000 = $44,000). The CDX investment estimate did 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 continued 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 (NPDES). 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 sites are covered by EPA’s 

Construction General Permit. Construction 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 requirements. 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 Management (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 before 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 incomplete 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 heavily 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 flow, 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 CDX data entry system to improve the quality of the 

data. After the data are certified by the operator, CDX 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 system 

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 data 
 CDX 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 has 

eliminated 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 the system. This backlog sometimes exceeded 1,000 

forms. On average, 33 days elapsed from the time a form was mailed until it was received by EPA, 

processed, and entered into the system. For the construction site operators that use the e-NOI system via 

CDX, the 33-day processing time has been eliminated. With 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 implementation 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 available 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 available 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 site where they can quickly obtain 

NOI status information. 

Additionally, use of CDX has made historical NOI and 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 has risen from approximately 30 percent availability to 

approximately 95 percent availability. Stated another way, before CDX was implemented enforcement 
 CDX 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 generally 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 monetary 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, the 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 with 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 $325,000 $325,000 $325,000 $1,950,000 

2 EPA FTE Costs $19,250 $19,250 $19,250 $19,250 $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 $11,000 $11,000 $11,000 $110,000 

8 Total costs for 

in-house, CDXlike system 

$605,500 $630,000 $321,500 $170,000 $170,000 $170,000 $2,067,000 
 CDX 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 $11,000 $11,000 $11,000 $110,000 

13 Total costs for 

CDX 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 reduction 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 reporting 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 being 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 processing costs and EPA FTE costs that would have 

been incurred in the absence of developing CDX. The Program Office’s estimated net gain of $228,652

divided by its estimated investment of $725,348 resulted 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 (OAQPS). 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 completed 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 modernization. Since the AQS data flow process had recently 

changed radically and was still in the 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 data flow operations. The OAQPS team that worked 

with the project team on this analysis indicated that their participation with CDX had been a positive 

experience. OAQPS expected future benefits from XML (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 

AQS No impact Anticipated impact Anticipated impact

No impact was 

anticipated or gained 

because AQS was 

already 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 transfers 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 services offered by CDX as a way to increase usability, 

system load, and, potentially, data quality at the time of submission. One specific Web service benefit 

OAQPS anticipated is increased data accessibility. OAQPS 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 accomplished. 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 paper to electronic reporting. Therefore, in this case, 

there was no basis for comparison of costs, as in the other 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 show that integrating CDX into EPA Program Office 

data flows produces monetary benefits as well as operational 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 monetary 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 where 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 between using CDX and developing an equivalent inhouse system. 

The purpose of presenting the monetary benefit information is to demonstrate a trend of monetary 

benefits from using CDX. Note that costs and benefit data are not comparable across data flows due to 

differences among data flows in the components of CDX 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 $230,152 
 CDX Business Case Analysis 

 

March, 2007 45 

As shown in Exhibit 10-1, although data for all cost elements and scenarios were not available for all data 

flows, sufficient data existed to identify distinct monetary benefits for five of the six programs included in 

the analysis. The following primary monetary benefit findings were made based on study data: 

• By using CDX Program Offices in this study avoided 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 already 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 reduced 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 was 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 operational improvements in timeliness, data quality, 

and/or accessibility as a result of CDX use. Operational 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 commonality 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 benefits 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 and accessibility, but did not conclude that it benefited 

from CDX in timeliness since that Program Office had 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), generally 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 timeliness, 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 

Paint 

Abatement 

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 inclusion 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 companies 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 electronic signature feature available in TRI through 

CDX. Considered in the context of an estimated 25,000 facilities who submit TRI data, this benefit is 

substantial. 

• Data availability in e-NOI to support enforcement actions rose from 30 percent availability to 95 

percent availability with the adoption of CDX. 

Anecdotal evidence of such benefits to EPA enforcement, 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 reduction; however, the operational benefits findings lead to 

the observation that use of CDX appears to reduce risks 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 benefits for several Program Offices and EPA as a whole, 

and has contributed to homeland security. For example, secure data transmission of the location of 

hazardous chemicals (TRI) and water supplies (SDWIS) means that CDX has decreased the possibility 

that this information may fall into the wrong hands. This topic merits further examination to acquire data 

that substantiates the role of CDX in reducing risks associated with environmental data exchange.
 CDX Business Case Analysis 

01-23-07 A-1 

APPENDIX A 

DETAILED TABLES OF TRI ESTIMATED COSTS 
 CDX Business Case Analysis 

01-23-07 A-2 

This appendix contains a series of six tables that provide 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 Office 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 $520,590 $495,800 $495,800 $471,010 

Disk $134,592 $122,336 $115,340 $115,340 $116,800 $116,800 $118,260 

Total $779,166 $708,210 $635,930 $635,930 $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 missing 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 21,000 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 $5,732 
 CDX 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 79,000 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 $11,156 $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 time. 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. Specifically, 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, Diskette, 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 45,000 25,000 15,000 

CDX or in-house, 

CDX-like system 8,273 24,708 30,000 35,000 40,000 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 $0.75 
 CDX Business Case Analysis 

01-23-07 A-4 

Table A-3. Estimated Costs of Paper, Diskette, 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 $65,700 $36,500 $21,900 

CDX or in-house, 

CDX-like system $6,205 $18,531 $22,500 $26,250 $30,000 $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 costs were used for FY2002 data submission through 

TRI using CDX. Table A-4 shows these costs and the projected costs to enter data from paper, diskette, 

and CDX over the study period. EPA FTE costs to develop 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 $247,900 $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 $436,132 $339,487 $3,692,529 

TRI program staff and CDX software engineers worked 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 Implement 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 $247,900 $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 $523,690 $493,970 $413,330 $5,173,631 
 CDX 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 implementing 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 $520,590 $520,590 $495,800 $495,800 $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 $11,000 $11,000 $77,000 

Total TRI 

w/paper and 

diskette 

submission 

$801,559 $730,603 $658,323 $658,085 $634,755 $634,518 $611,188 $4,729,032 

TRI using in-house CDX-like system 

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 $247,900 $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 $523,690 $493,970 $413,330 $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 $247,900 $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 $366,599 $353,387 $436,132 $339,487 $3,692,529 
 CDX 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 TRI 

w/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