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US EPA Electronic Reporting Rule for NPDES Piles Pressure on Paper-Based Water and Waste Water Disclosure Processes

Verdantix research with EH&S managers working at firms with less than $2 billion in annual revenue constantly unearths ongoing use of paper-based processes. Our recent global survey of 312 EH&S senior managers found that only 13% use software for water and waste water management – the least digitized process across 12 core EH&S processes we analyzed. So it comes as no surprise that the US EPA has pushed out a mandatory electronic reporting rule for the National Pollutant Discharge Elimination System (NPDES) which is intended to replace all paper-based Clean Water Act NPDES permitting and compliance monitoring with electronic reporting.

Drilling down into the survey data, water and waste water management is also the process with the lowest percentage of enterprise scale software deployments. Sixty-four per cent of firms use software at an enterprise level of water and waste water reporting, 24% at business unit level and 12% at the facility level. Globally this means just 8% of firms with revenues above $250 million use software for their water and waste water management at an enterprise level.

The NPDES electronic reporting rule is intended to ensure there is more consistent, timely and complete reporting nationwide. Regulated entities should note that the information required is not changing, simply the method of delivery. The EPA is offering technical and financial assistance to US States to make the transition from paper-based processes to digital filing. The EPA is not requiring regulated entities to use an EPA-developed electronic tool. Firms and public bodies can either use EPA software, state-authorized NPDES software or third-party software from a supplier like IHS, Intelex or SAP.

Many states, tribes and territories already use the NetDMR tool to submit Discharge Monitoring Reports (DMRs) to the EPA. Within one year of the effective date of the final rule, which will be October 2016, all data in Discharge Monitoring Reports and Sewage Sludge/Biosolids Annual Program Reports must be submitted electronically. Within five years of the effective date EPA and authorized state NPDES programs must electronically collect, manage and share all remaining NPDES program information.

The digitization of environmental data management by the EPA is a positive driver for investment in EH&S software platforms which reduce costs in data collection, processing, aggregation and auditing. Consulting firms with deep federal and state relationships such as CH2M, Deloitte and CGI may benefit more directly from the EPA digitization strategy than software vendors but the underlying direction of travel is a positive market development. To learn more about EH&S information management best practices attend the Verdantix EH&S Information Management Summit in Chicago, May 16-18 2016.