EPA305-F-10-001
Case Study: Ohio Environmental Protection Agency's Electronic Discharge
Monitoring Report (eDMR) System Reaches 99% Adoption
Introduction
This Case Study highlights how the Ohio EPA
launched its eDMR system, which uses electronic
reporting to allow permittees to report their
discharge measurements quickly and easily online.
This method of reporting, currently at a 99.9%
adoption rate, has increased data quality and
improved environmental protection, while also
saving significant time and resources for all
stakeholders. Through interviews and data
collection, this case study covers the background,
challenges, implementation and impacts that the
eDMR system adoption had on both permittees
and the state of Ohio.
Background
Ohio EPA decided to collect its water discharge
monitoring data electronically, eliminating paper
forms. In 2005-2006, the Ohio EPA collected 70%
of its water discharge information through a
software program called SwimWare. The remaining
30% of their data was still collected through
traditional paper forms. Unfortunately, both
methods were labor intensive for permittee and
the Ohio EPA. The SwimWare program required
downloading, installation, and extensive technical
knowledge. Data could not be easily updated for
errors or for altered permit conditions. Meanwhile,
paper forms were often illegible and data were
often omitted. Therefore, both methods of data
collection resulted in lower data quality.
The Clean Water Act of 1972
delegated to authorized
states the authority to
regulate surface water within
their borders by maintaining a
permit program. Any
regulated entity discharging
pollutants into surface water
owned by the state is required
to have a National Pollutant Discharge Elimination
System (NPDES) permit. NPDES permits allow
states to control the quantity of pollutants being
discharged into their waters, and require
permittees to monitor and report their discharges.
This process is intended to ensure compliance with
state and federal regulations that protect public
health and the environment.
Since 1972, the US EPA has required the collection
of water discharge monitoring data mainly through
paper forms. Filling out these forms was labor
intensive, requiring permittees to fill them in
manually and submit them to either the state or
federal agency. The state or the US EPA then
manually scanned and verified the data. This
process led to some data loss, making it difficult
for states and the US EPA to monitor, enforce, and
track the progress of clean surface water initiatives
in the US.
Nationally, it is reported that 11% of
US EPA data analysis is solely
dedicated to water discharge
collection—the largest of any
environmental program.
Challenge
Given their experience with
SwimWare and permittees,
the Ohio EPA sought a new
data collection system that
would allow permittees to
input discharge amounts
easily through an online
application. The intent was to
reduce the labor associated with processing the
information and increase data quality. Early in the
development process of its eDMR system, the Ohio
EPA recognized several challenges including
outreach, buy-in, and training.
Ohio Implementation
The Ohio EPA faced major challenges including
raising permittee awareness and creatingthe
desire and ability to learn and use a new eDMR
system. To address these challenges, the Ohio
EPA took a phased approach to roll out eDMR.
The Ohio EPA also included various methods to
communicate the benefits of the eDMR system
and to train permittees on the new system.
This approach appears to have led directly to the
successful implementation and adoption of the
Ohio eDMR system.
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Roll Out
The Ohio EPA focused on meeting the US EPA's
technical requirements, including the Cross-Media
Electronic Reporting Regulation (CROMERR)
compliance, prior to roll out. CROMERR provides
the legal framework for electronic signature
verification and establishes standards for
information systems that receive reports and other
documents electronically.
The Ohio EPA also piloted early versions of the
system with permittees that were SwimWare
power-users in order to document their responses,
incorporate their feedback, and refine the system
in later versions. By focusing on meeting these
requirements and engaging permittees from the
beginning, Ohio EPA was able to develop a system
that met long-term agency and permittee needs.
Next, the Ohio EPA focused on rolling out the
eDMR system to each of the five Ohio EPA districts.
Each month, the Ohio EPA invited each district, one
by one, to use the new system. This allowed them
to concentrate their communications and training
on a smaller, individualized audience. Workingwith
smaller groups allowed the Ohio EPA to address
the unique needs of each district and create
individualized training workshops, which further
facilitated adoption. As Figure 1 indicates, the Ohio
EPA was able to increase the number of eDMR
users each month.
eDMR System Ad option
2OO7-2OO8
3000
1000
^
Number of
Reporters
> 0
o a>
-ill
a>
Figure 1: Ohio eDMR system Adoption by Month
Ohio EPA also designated a point of contact, or
"relationship manager," for each district. The
relationship managers became the primary
sources of information for permittees needing
assistance with the new system. The relationship
managers were vital for increasing the number of
permittees successfully usingthe system.
Communications
The Ohio EPA realized that permittees who were
unaware of the new system, or only had a limited
understanding of its value, would be less likely to
adopt it. So the Ohio EPA conducted a permit
holder analysis to mitigate this risk. They found
that a majority of permittees preferred phone calls
and e-mail communications.
They also found that these permittees were not
interested in complex videos or the latest
technologies. These permittees were satisfied with
simple and easy to understand communications
that were timely and instructive. The
communications focused on spreading awareness
of the new system and its benefits so permittees
would want to learn more. Ohio EPA also reached
out to external governance groups and industry.
They distributed flyers and brochures to water
affiliates including the Ohio Water Environment
Association to broaden their outreach.
Ohio EPA focused on the remaining 800 "paper
form" permittees. Each year, they sent out new
blank discharge monitoring forms to those
permittees a long with an attached flyer
recommending that they use the eDMR system
and eventually transitioned them to a request only
procedure. The Ohio EPA made personal phone
calls to the paper form permittees to individually
encourage them to use the eDMR system. Many
permittees quickly transitioned because the focus
on personal contact remained central to the Ohio
EPA's approach.
Training
Many permittees cite the difficulty of learning new
systems as an impediment to frequent and correct
usage. The Ohio EPA supported the need for robust
training to draw permittees into the new system.
Efficient and diverse training opportunities and
information dissemination eased permittees into
the new system and reduced the time needed to
engage interest.
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First, Ohio EPA created an online "All in One"
training document that had screenshots and
descriptions of the entire reporting process.
Continuing their focus on personal attention, the
Ohio EPA also held in-person training at the various
districts each month. They filled over 100 seats at
each training event.
The Ohio EPA was aware that Operators, who often
prepare reports for permittees, were required by
the state to complete a certain amount of
training/coursework each year. The Ohio EPA
leveraged this requirement to gain approval for
their free three-hour eDMR system training
workshop to fulfill certification requirements to
maintain an Operator's license.
The Ohio EPA started each training session with an
hour and a half PowerPoint presentation followed
by a live demonstration of the system with a permit
holder or Operator from the audience. The "permit
holder" would create his/her account on the spot
to exhibit the system's ease of use. Eventually,
positive word of mouth about Ohio EPA's eDMR
system and the ease of submitting discharge
monitoring reports electronically led to more
invitations to conduct workshops at regional
conferences and other events.
Result/Outcome
The Ohio EPA made significant strides in increasing
the number of electronically reporting permittees,
decreased the amount of time spent managing the
program, and improved data quality to ensure
compliance. Ohio's successful implementation of
"I used to dedicate over 40 hours a week to
this program answering hundreds of e-mails
and phone calls by permit holders. After the
deployment of Ohio eDMR system, I've been
able to reduce my level of effort 75 percent
to just 10 hours a week." - Ohio EPA
Employee
its eDMR system was due in part to a well-planned
and executed roll out strategy that included diverse
communication and training. Over 99% of Ohio
permittees now use the eDMR system (Figure 2).
Percentage of Ohio Reporters using
eDMR System vs. Paper Forms
1.00%
i eDMR System
i Pa per Forms
Figure 2: Ohio Permittees using eDMR system
Prior to eDMR, Ohio EPA needed five full time staff
members to support the DMR program. During
eDMR roll-out they reduced support to two staff
members. They now run the program without any
full-time staff. The automated compliance tools
within the eDMR system inform permittees if their
discharges exceed their authorized permit limits or
if there are data errors. Most of the data errors are
user errors and with the new system permittees
can go back quickly to correct the errors.
As a result, errors have dropped from 50.000 per
month to 5.000 per month, giving the Ohio EPA
more accurate and robust data, which translates
into improved data quality. With improved data
quality, Ohio EPA is able to better target areas of
pollution, which further improves Ohio's
enforcement and compliance program.
Conclusion
The Ohio EPA created an eDMR system that saves
time and resources for the state and permit
holders while dramatically improving data quality.
The implementation of the eDMR system has
improved the ability of Ohio EPA to monitor and
enforce compliance with the Clean Water Act.
Higher data quality and operational efficiency
facilitates the agency's mission to protect human
health and the environment.
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Key Lessons Learned
Roll Out
Ensure CROMERR-compliance, and engage permittees from the beginning to develop your system
Segment the roll out of an eDMR system to allow for customized communication and training
Provide a relationship manager to alleviate anxiety and address pressing questions and concerns
Communications
Understand your stakeholders and their communication preferences
Consider using time intensive tactics such as phone calls to win over resistors
Develop partnerships with associations and other like-minded organizations in your state to broaden your
outreach
Receive accreditation for eDMR system training to provide an incentive for attendance
Build out Help resources for the eDMR system and use forum boards or e-mail to answer questions quickly
Offer training both in person and virtually to increase speed of adoption
Ohio EPA eDMR System Team and EPA NetDMRs Contacts:
Name
Chris Bowman
Randy Crowell
Jamie Roberts
Adele Vogelgesang
Catherine Bius
Nasrine Lescure
Allison Donohue
Role
Ohio EPA Information Resource
Management (IRM) Manager for
Division of Surface Water (DSW)
Ohio EPA Data Administration Manager
DSW
Ohio EPA eDMR Administrator DSW
Ohio EPA Information Technology (IT)
Manager, IT Services
US EPA NetDMR Training Lead
US EPA NetDMR Technical Lead
US EPA NetDMR Communication and
Outreach Coordinator
E-Mail
Chris.Bowman@epa.state.oh.us
Randy. Crowell@epa.state.oh. us
James. Roberts@epa. state. oh. us
Adele.Vogelgesang@epa.state.oh.us
Bius.Catherine@epa.gov
Lescure.Nasrin@epa.gov
Donohue.Allison@epa.gov
Additional Information/Resources
Ohio EPA eDMR system Information Page: http://www.epa.ohio.gov/dsw/edmr/eDMR.aspx
Ohio EPA eDMR system Training Guide: http://www.epa.ohio.gov/dsw/edmr/eDMRtraining.aspx
Ohio EPA Link to Answer Place: http://ohioepa.custhelp.com/cgi-
bin/ohioepa.cfg/php/enduser/std alp.php?p sid= NxrDJ-i
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