Benefits of Net DMR to States
SLIDE 1 – Discharge Monitoring Report Collection and Entry
Reporting of discharge monitoring information, and associated data collection takes 13.3
million hours per year (representing more than 11% of all burden hours associated with
EPA information collection).
Reporting is normally required monthly (and in some states daily) for each pipe and
parameter.
Some facilities may have hundreds of outfalls and pipe/parameter combinations.
The vast majority of Discharge Monitoring Reports are reported and collected in
hard copy.
In order to make use of this valuable information, EPA and state agencies need to
manually key-punch the data into a format that allows automated comparisons of limits to
measurement. This is how EPA and states can quickly ascertain where problems occur.
Some states do not have the resources to key punch all the DMRs received, which leaves
information “un-used” or requires burdensome manual review of hard copy files to
identify violations and then manually do complex calculations to idenify SNC.
SLIDE 2 – NetDMR – Background
Electronic reporting of DMR information significantly reduces the reporting burden on
the regulated community, and the data entry burden on EPA and state governments, while
at the same time, raising the quality and completeness of the information.
Several states have piloted electronic DMR reporting. Their efforts help provide EPA
with national projections regarding possible cost savings to the regulated community and
government.
A coalition of states is now working with EPA to build a national application called
NetDMR. This will work with ICIS-NPDES.
Preliminary projections indicate that cost savings to industry and government will range
from $50-$100 million per year.
SLIDE 3
Business Reasons/Need for a National Network electronic DMR program
(NetDMR).
list 5 business reasons below in a summary slide
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SLIDE 4
Business Reason 1 – Electronic reporting is faster, easier, and cheaper for
government agencies.
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Cost savings to government are estimated at $150 per year for each facility that
switches from hard copy reporting to electronic reporting.
Assuming 50% of eligible reporters take advantage of electronic reporting, this
saves about $3 million per year, or more than $6 million in efficiencies (moving
from electronic to paper) if reporting was 100% (e.g., mandatory reporting).
A 2006 EPA-State “Return on Investment” Study (to government) concluded that
electronic DMR flows provided the highest return on investment of the five large
data flows studied.
SLIDE 5
Business Reason 2 - The transition from paper to electronic reporting significantly
reduces burden on the regulated community.
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Based on pilot studies in Michigan, savings to facilities that switched to electronic
reporting was between $1,000-$2,000 per facility.
This translates to between $20 and $40 million per year in cost savings to the
regulated community if half of the permittees took advantage of electronic
reporting.
If all reporters used electronic reporting total savings to industry could be more
than $80 million.
SLIDE 6
Business Reason 3 - Quality and timeliness improvements accrue from electronic
reporting and will lead to better data.
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Studies of other electronic reporting projects in Federal agencies, and within EPA
suggest that the error rate will be cut to less than 1%. While EPA does not have
an exact error rate for the “key punching” method, it is substantially higher than
1% because it relies on proper interpretation of handwriting, proper key punching,
and timely entry.
EPA estimates that the date between data reporting and availability for use will be
cut by at least 30 days, and perhaps up to 120 days in some states.
Several recent EPA Inspector General audits have criticized the completeness and
quality of the data in the national system.
SLIDE 7
Business Reason 4 – Availability of data will improve implementation of NPDES
programs – allowing less focus on “compliant” facilities, and more focus on those
problems that could cause water quality impairment.
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Despite the high volume of paper DMRs coming into EPA and the states, the
information cannot be efficiently used unless the values are key-punched into the
database (which will allow easy analysis of violations).
NPDES program implementation (which in some respects hinges on availability
and quality of DMR data in an electronic format) has been the subject of
numerous Inspector General reports, public interest group reports, and newspaper
articles.
NetDMR will increase breadth of the information available to decision makers
because reports previously put into hard copy files with little or no analysis will
be entered into a modern information system (ICIS-NPDES) and noncompliance
evaluations automatically performed by the system..
SLIDE 8 – Examples of “Questions Answered” Leading to Improved Management
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Program management questions that could be answered include:
Which facilities in a priority watershed are currently out of compliance?”
Of those, which have not received inspections?
Are they clustered together?
Is the watershed impaired for the pollutants that are in violations?
Which major facilities are significantly below limits? Does it make sense
to inspect several smaller facilities with frequent violations rather than a
compliant large facility?
o Which side of the river are violators concentrated (particularly important
when river is the border between two states for watershed planning).
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SLIDE 9
Business Reason 5 – There are significant cost savings to the nation’s taxpayers of a
national NetDMR application as the costs of developing and supporting multiple
similar systems in states are avoided. .
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State Use and Savings
o A growing coalition of about 15 states are leading initial system
development and have asked EPA to host/manage the NetDMR system.
o EPA has direct responsibility for running the NPDES program in 5 other
states plus territories (thus will use NetDMR).
o For these 20 states (does this include GM?NO), with a 50% adoption rate,
the savings to industry would be approximately $11 million (this assumes
7,500 users times $1,500 in savings per user), and the savings to EPA and
states would be $1.1 million (7,500 times $150). [For these 20 states,
since the states are known, could we do an estimate in which we add up
the number of permittees and thus get an actual estimate? Yes, I’ve done
that, and will send you a spreadsheet]
o Additional savings accrue in “avoided” development costs.
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o EPA assumes that at least 18 more states will use NetDMR because of the
cost benefits to them.
 At a 50% adoption rate,
 A state with few facilities may expect to save about
$125,000/yr.
 An average state may expect to save $225,000 per year.
 A large state may expect about $500,000 million in savings
per year.
 Additional savings accrue in “avoided” development costs.
o States that do not use NetDMR may use some components of it (code will
be sharable).
SLIDE 10 – National View (Savings)
o National Cost Savings at 50% user rate in 38 states are:
 About $2.3 million yearly.
 About $10 million on one time development cost.
o Projections above are still being developed (subject to some change, but
“in the ballpark”).
o Operations costs for EPA to run the system are under development (EPA
anticipates this will be less than $1 million per year).
SLIDE 11 – Summary of Business Need for NetDMR
Development of NetDMR has many significant benefits. While EPA has not finished its
projections, it is safe to assume that:
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Regulated community will save about $50 million per year.
The government stands to save at least $2 million per year in efficiencies (paper
to electronic) if NetDMR becomes the standard reporting method.
Central EPA hosting of the system will save the states an additional $17 million in
avoided operation and maintenance costs (this assumes all states eventually want
electronic reporting).
An additional savings of about $10 million come from “avoided state
development.”
These savings figures make an EPA investment in NetDMR (projected to be less
than $1 million per year) an extremely attractive option.
Possible small footnotes for page….
These findings are supported by statistics gathered by states that have piloted this
approach, and specific “Return on Investment” studies that EPA and the states
have developed.
Uncertainties exist in regard to facility adoption rates, but EPA believes
eventually that electronic reporting will become mandatory.
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