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EPARulemakingEPA-HQ-OECA-2009-0274

National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule

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Last modified
Apr 9, 2022
Comment window
closed 4197d ago
American Gas Association filings
1

Activity

American Gas Association filed 1 comment on this docket between Oct 31, 2013 and Oct 31, 2013. 58 other organizations filed here. The comment window closed 4197d ago.

What American Gas Association filed (1)

Oct 31, 2013· Comment submitted by Arushi Sharma, Counsel, Regulatory Affairs, American Gas Association (AGA)· EPA-HQ-OECA-2009-0274-0216

Attached are comments of the American Gas Association, responding to the Environmental Protection Agency's Notice proposing a nationwide NPDES Electronic Reporting Rule program. (See Proposed Rule, 78 Fed. Reg. 46006 (July 30, 2013)). AGA's comments support improvements to the NPDES framework to achieve a consistent nationwide electronic reporting program across all states, tribes and territories that administer the reporting program. Our comments note that AGA members will be affected by changes to the NPDES reporting program because gas utilities routinely submit documents and information for coverage under state and federal construction stormwater general permits, as well as inspection documentation under those permits for routine utility land disturbances. Our comments also note that in addition to state-wide and regional EPA permitting requirements, utilities are often required to submit permitting and compliance information to comply with municipal construction stormwater permitting programs. Accordingly, our comments request that EPA issue a supplementary notice for public comment that provides greater specificity to the proposed reporting requirements with regard to any mandatory or "threshold" compliance requirements for all electronic programs. We also request that any new mandatory reporting requirements should be phased in over a period of time, with provisions to grandfather existing state programs to promote the efficient administration of existing electronic reporting frameworks. Please contact us at the information below: Arushi Sharma, Counsel, Regulatory Affairs American Gas Association asharma@aga.org | 202.824.7120 | 400 N. Capitol St., NW, Washington DC 20001

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Abstract

EPA is proposing a regulation that would require electronic reporting for current paper-based NPDES reports. This action will save time and resources for permittees, states, tribes, territories, and EPA while improving compliance and providing better protection of the Nation’s waters. The proposed Clean Water Act regulation would require permittees and regulators to use existing, available information technology to electronically report information and data related to the NPDES permit program in lieu of filing written reports. The proposal will also allow better allocation and use of limited program resources and enhance transparency and public accountability by providing regulatory agencies and the public with more timely, complete, accurate, and nationally-consistent sets of data about the NPDES program and potential sources of water pollution. The benefits of this proposed rulemaking should allow NPDES-authorized programs in states, tribes, and territories to shift precious resources from data management activities to those more targeted to solving water quality and noncompliance issues. This in turn may contribute to increased compliance, improved water quality, and a level playing field for the regulated community. Given the large scope of this proposal, EPA commits to offer an additional opportunity for transparency and engagement by publishing a supplemental notice should we receive comments on the proposed rule that require significant changes. States, tribes, territories, permittees, and other stakeholders can review and comment on the supplemental notice. EPA plans to publish the supplemental notice within 180 days after the public comment period for this proposed rule has closed.

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Co-filers (58)

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