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December 19, 2016
The unease of environmental e-reporting
By Emily Remmel, JD, Legal Editor

Not long ago, the standard practice for environmental reporting included filling out ready-made forms by pen followed by mailing or faxing the document to the respective federal or state agency. As the digital age progresses, and regulators are favoring online reporting (i.e., electronic reporting, or e-reporting), the “old-fashioned” method of using a pen and paper is highly likely to go extinct.

It’s easy to get uneasy about e-reporting. Not many folks look forward to reporting site-specific information to state or federal agencies. However, the reporting must be done.

A variety of regulatory programs require some type of e-reporting through the U.S. Environmental Protection Agency’s (EPA) Central Data Exchange (CDX), including Emergency Planning and Community Right-to-Know (Tier II and TRI) and National Pollution Discharge Elimination System (NPDES) permitting. It is expected that more federal and state environmental regulatory programs will make this transition to e-reporting. Note: NPDES permittees have until December 21, 2016, to electronically submit Discharge Monitoring Reports (DMRs).

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Common headaches with e-reporting

By recognizing in advance the possible pain points associated with e-reporting, it will be less stressful when it comes time to file.

Time-consuming advanced registration. EPA’s CDX program and states with online reporting systems require users to register by creating an account in advance of reporting. You must determine the proper person to be the registrant or signatory as well as who else will need access and the ability edit reports. The registration process itself requires establishing your identity, relating yourself to the facility, and verifying your signature. All of this takes extensive time, and serious hiccups may occur in this initial registration period. As a result, last-minute reporters could easily find themselves pushing the regulatory reporting deadline due to the registration requirements.

Web browser incompatibility. There are many web platforms for users to peruse the internet, such as Mozilla Firefox, Google Chrome, Internet Explorer, Safari, and Microsoft Edge, among others. However, this versatility is problematic for agencies because they simply cannot make their e-reporting systems compatible with every browser.

Others don’t do their part. Sometimes other individuals (e.g., filers, reviewers, installers, operators, third-party certifiers) or companies have to contribute to your e-reporting for work they have completed. It is important to stay connected with these individuals to ensure they complete their portion of the reporting—otherwise, your e-reporting is not complete.

Tips and tricks to e-reporting

E-reporting can be easy if you pay close attention to the following simple tips and tricks.

Manage time effectively. Do not wait until the last minute to electronically report your environmental data. Complete the signatory registration and account set up well in advance of the deadline. Set deadlines for others in your office to have all compliance data submitted by a certain date. Therefore, when the deadline nears, you are not scrambling to find missing information.

Use an effective file management system. All too often we waste a considerable amount of time trying to find the right information on our computers or in our filing cabinets. Although often easier said than done, an essential strategy is creating an effective method for storing electronic files. Try to avoid saving unnecessary documents, and create a consistent method for naming files and storing them.

Request a waiver. In some situations, a waiver from the e-reporting requirement is necessary. But beware, these waivers are usually intended for those with specific hardships (i.e., no internet access or disabilities). Regulators have been known to deny waivers for claims of internet ignorance, as well as waivers submitted via e-mail with the claim of lack of internet access.

The new era of next generation compliance

The EPA has unveiled an integrated plan to propel compliance and enforcement into the 21st century. The plan is called Next Generation Compliance, or Next Gen. The goal is to move the EPA from the current reaction-based enforcement strategy to a contemporary approach that favors advanced technology and real-time data reporting. In addition, the EPA wants to facilitate transparency, meaning certain unprivileged data will appear online for the general public.

As the EPA and states move toward e-reporting as the primary mechanism for reporting, it is important to input your data correctly the first time. It is equally important to double check that the information the EPA or state puts online for the public is accurate. Otherwise, your facility may find itself in a difficult and lengthy battle to get the information corrected online.

E-reporting may be reassuring because the process is more streamlined and likely to eliminate middleman errors that occur from inputting data by hand, but the process can be onerous if you don’t have the adequate technology, are unorganized, or simply procrastinate too close to the filing deadline.

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