September 27, 2006
MEMORANDUM
Subject:Request for Representatives for the Regional NetDMR Advisory Board
From:David Hindin, Director (s)
Enforcement Targeting and Data Division
To:Denny Dart, Region 1
Nestor Louis, Region 2
Debra Forman, Region 3
Mike Donehoo, Region 4
James Coleman, Region 5
Cathy Bius and Helen Nguyen, Region 6
Linda McKenzie, Region 7
Sandra Johnson and Josie Lopez, Region 8
Roger Vann, Region 9
Diane Davis, Region 10
On September 6, OECA hosted a Regional call to discuss the NetDMR (Network Discharge Monitoring Report) project. Development of the NetDMR reporting tool is governed by a Steering Committee consisting of representatives from Texas, West Virginia, Illinois, OECA, and OEI. As noted below, we are also forming a NetDMR Regional Advisory Group to ensure that Regional interests are properly represented during the development process. At the September 6th call, you were identified as the lead contact(s) in the Region on this project. Beyond your role as the lead Regional contact, we are requesting that several of you (or other Regional staff/managers) consider taking on additional responsibilities.
To provide some background, when the NetDMR tool is completed, EPA intends to manage and host the systemso that any state can offer electronic reporting to its NPDES permittees. In our discussions with the states, they do not believe that any state will have gained final CROMERR approval at the time the NetDMR tool opens its doors. In light of this, they have indicateda preference that EPA pilot the tool as soon as possible in jurisdictions where EPA is the sole permitting authority.
During our conference call, each Region indicated that they have some permittees that are under direct federal jurisdiction. Some Regions (1, 2, 3, 6, 9, 10) have responsibilities for complete states, districts, or territories, while other Regions have responsibility for specific facilities (e.g., those on Indian Lands, off-shore oil platforms, etc.). To ensure that the NetDMR system adequately handles our needs across a diverse mix of facilities, I am requesting volunteers to serve on a Regional NetDMR Advisory Board that will advise EPA and the states on a series of issues. The Advisory Board should consist of staff or managers from at least three different Regions. We think that Regions with substantial direct implementation responsibilities should strongly consider participation on the Advisory Group.
NetDMR Regional Advisory Group Charge
A.Identifying Pilot Participants. Identify permittees willing to participate in focus group and pilot-testing phases for the beta NetDMR tool. Ideally, the Advisory Board will identify at least one facility per Region that can participate.
B.Consulting on the Overall Design of the Project. Participate as needed in the requirements development process that will be led by the NetDMR contractor. This includes identifying subject matter experts in the Region for particular issues where the contractor must clearly understand the Regional business process used to process DMRs (including consulting on what the normally procedures are for allow facilities to amend previously submitted DMRs). The Advisory Group will also play a role in usability testing.
C. Developing components of the NetDMR CROMERR approval package. While OECA and the States will take the lead on ensuring the NetDMR software itself is CROMERR-compliant, the Advisory Board will develop parts of the CROMERR application that relate to the Regional-specific responsibilities (e.g., managing wet signature copies, administering users/passwords, defining the scope of users that are eligible to use the NetDMR tool across the country, etc.).
D. Developing a Regional Implementation Guide. As the project nears completion, the Advisory Committee should complete an implementationguidance that Regions should follow when administering NetDMR. This will cover areas such as:
- assigning a Regional system administrator that can issue passwords to the permittee,
- authorizing permittees to begin reporting (which involves confirming that all limits are properly entered in ICIS-NPDES),
- procedures for storage of wet copy signature agreements that are submitted by facilities, and
- suggested approaches for performing outreach to the regulated community (such as mailings to facilities that are eligible to begin electronic reporting).
E. Developing an Implementation Sequence for Permittees Under Primary Federal Jurisdiction. The Advisory Group will make recommendations on whether all facilities under Federal jurisdiction should be eligible to report when NetDMR opens its doors, or whether a phase-in is required.
F. Coordination and Training with Other Regions As Necessary.
We will also consult with the Advisory Group on other important issues as necessary on other key issues. For example, we will be looking for input on whether it is feasible to require electronic reporting at the time of permit renewal.
We hope you will consider serving on the Advisory Board. As a rough estimate, we anticipate that the commitment level will be roughly 10-15% of your time from October, 2006 – December, 2007. Your time investment will lead to significant workload reductions in the long-term for the Regional offices – particularly as our hard copy management processes are phased out. Please reply to me or Mike Barrette by October 4thif you would like to serve on the Advisory Board.
cc: Regional NPDES Branch Chiefs
Michael LeDesma
Kenda Layne
Roy Chaudet
Amelie Vandenbos
Alison Kittle
Pravin Rana
Andy Battin
1