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NPDES e-Reporting Rule

  1. Proposed Rule Basic Information
  2. Will the Proposed Rule lead to Federalism implications?
  3. When will the Final Rule take effect?
  4. How does the current system differ from the one being proposed?
  5. Who would be affected by the Proposed Rule?
  6. What data will be required to be submitted by NPDES-regulated facilities electronically?
  7. More...
  1. Reporting Requirements
  2. Who will be granted a temporary waiver from the proposed rule?
  3. What is EPA's approach going to be regarding states that already provide e-reporting for their NPDES permit holders?
  4. Many states have a different certification statement for Whole Effluent Toxicity (WET) testing. How will this be accommodated?
  5. Just to clarify - the Rule will not change requirements for data entry by the states?
  6. Some states require co-permittees on stormwater construction Notices of Intent (NOIs). - both the owner and the construction contractor(s). How will electronic reporting support this?
  7. More...
  1. Data Systems and Electronic Rules
  2. CROMERR approval has been an issue for state electronic reporting, particularly the states with their own electronic reporting systems. How will EPA manage all the CROMERR approvals necessary to comply with the implementation schedule?
  3. How do this Proposed Rule and NetDMR relate to each other?
  4. How will EPA incorporate the current electronic reporting software for biosolids, i.e. Biosolids Data Management Software (BDMS), it developed several years ago?
  5. Which states do not have proposed or existing eDMR/Net DMR systems?
  6. Are there any set dates for NetDMR, EPA’s tool for reporting Discharge Monitoring Reports (DMRs), training in the near future?
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  1. Implementation Plan
  2. Would a state that administers its own PDES (Pollutant Discharge Elimination System) program, such as Kentucky (KPDES), follow the same timeline of implementation or would they need to promulgate their own programs that follow the national program?
  3. Why is implementation starting so soon after the promulgation of the Final Rule?
  4. What does Phase 1 and Phase 2 of the Proposed Rule implementation plan entail?
  1. Economic Analysis
  2. Who will finance the change from paper data entry to electronic for the small dischargers?
  3. Which 9 states were surveyed for the economic analysis?
  4. How much will be saved under the Rule?
  1. Sector-Specific Issues
  2. Municipal Separate Storm Sewer System (MS4s) Many annual program reports for municipal stormwater permits, is in narrative form, not very conducive to simple data entry. How might this change for e-reporting?
  3. Municipal Separate Storm Sewer System (MS4s) Does the MS4 Program Reporting fall under Phase I or Phase II proposed implementation timelines?
  4. Combined Animal Feeding Operations (CAFOs) Are CAFOs being singled out for scrutiny by EPA more than other point sources?
  5. Combined Animal Feeding Operations (CAFOs) There are a large number of data items that will have to be submitted by CAFOs on an annual basis. A number of these will have to be supplied on a field specific basis, compounding the number of data items by the number of fields receiving CAFO manure. Why does the accompanying economic analysis to this Proposed Rule indicate that time involved in assembling and submitting the data on an electronic basis is negligible?

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