State Reporting Burden Reduction Initiative: Progress Report, September 2008


State Reporting Burden Reduction Initiative
               Progress  Report
                        September 2008
     U.S. Environmental Protection Agency
     Document No. EPA-230-K-08-001

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Table of Contents
Executive Summary 1

1.0 Introduction 3
1.1 Background and Purpose 4
1.2 16 Priority Categories 4
1.3 Improving Transparency and Clarity 6
1.4 Tools for Making Burden Reduction Part of EPA's Standard Business 7
1.5 Overview of Progress 8
1.6 How To Use This Report 9

2.0 Priority Areas 12
Priority Area 1. Regional Clean Air Act (CAA) Sectionl 05 grant reporting 13
A2. Reduce Reporting Frequency for CAA Section 105 Grant Reporting 45

Priority Area 2. CAA Prevention of Significant Deterioration/ New Source 15
Review (PSD/NSR) and Section 112(g) Reporting
A6. Eliminate Report on "No Determinations" Under CAA Section 112(g) 47
A7. Eliminate Report on PSD/NSR Non-Applicability Determinations 48

Priority Area 3. Clean Water Act (CWA) Section 303(d) and 305(b) 16
Integrated Reports
Wi 6. Keep CWA Sections 303(d) and 305(b) Reports Separate 95
W30. Reduce Frequency of 303(d) and 305(b) Integrated Reports 104

Priority Area 4. CWA Non-Pojnt Source Report 18
W22. Streamline Non-Point Source Report 99
W24. Harmonize Water Reports with Different Reporting Periods and
Frequencies 100
Priority Area 5. Compliance Reporting Under the National Pollutant
Discharge Elimination System (NPDES)
E4. Eliminate NPDES Annual Noncompliance Report (ANCR)
E12. Eliminate NPDES Semi-Annual Statistical Summary
E26. Reduce Frequency of NPDES Quarterly Non-compliance Report (QNCR)
W4. Eliminate Quarterly Electronic Permit Issuing Forecasting Tool (E-PIFT)
Report
W23. Reduce Reporting on Draft Major and Minor NPDES Permits
Priority Area 6. Integrated Compliance Information System/ Permit
Compliance System (ICIS/PCS) Requirements
E1. Reduce ICIS Data Requirements
E2. Reduce Data Elements in ICIS' Required Integrated Compliance
Information System Data Elements (RIDE)
E3. Streamline Data Requirements in NetDMR for NPDES Discharge
Monitoring Reports (DMR)

58
63
69
90
99

56
57
57
20
22

Priority Area 7. Duplicate Enforcement Reporting 24
E5. Eliminate Reporting Enforcement and Compliance Assurance Priorities
(RECAP) Report 59
E6. Eliminate or Reduce Frequency of CAA, CWA, and Resource
Conservation and Recovery Act (RCRA) Quarterly Watch Lists 59
E14. Eliminate Annual Monitoring Report Under CAA Section 105 63

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E16. Eliminate Requirement to Submit NPDES Enforcement Documents 65
E17. Eliminate Significant Industrial User (SIU) Semi-Annual and Annual
Reports 65
E24. Use Performance Partnership Agreement (PPA) for Enforcement
Reporting 68
E27. Eliminate the Annual Public Water System (PWS) Compliance Report 69
E29 Consider State Notices of Violation (NOVs) To Be Formal Actions 70

Priority Area 8. Enforcement and Compliance History Online (ECHO) 26
Web interface
E7. Improve Data Management in ECHO 60
E1 0. Eliminate Reports that Can Be Retrieved from PCS or ECHO 62

Priority Area 9. Performance Partnership Grant (PPG)/PPA Categorical 28
Grant Reporting
G5. Eliminate Reporting on State-Based or Other Programs Not Federally
Funded 73
G6. Reduce PPA/PPG Reporting Frequency 73
G9 Streamline PPA/PPG Reporting Requirements 75

Priority Area 10. CWA Section 31 1 9 Grant Reporting 30
W15. Eliminate Annual Summary of CWA Sections 106 and 319 Quarterly
Reports 94
W1 8. Modify CWA Section 31 9 Grant Reporting and Tracking System (CRTS) 97
W36. Reduce Frequency of CWA Section 31 9 Reporting 1 09

Priority Area 1 1 . Disadvantaged Business Enterprise (DBE) Utilization 32
Reporting
G7. Reduce Reporting Frequency on Disadvantaged Business Enterprise
(DBE) Utilization 74

Priority Area 12. Underground Injection Control (UIC) Reports 34
W17. Streamline UIC Reports 95
W26. Provide Funds or Reduce Requirements for Class V UIC Program 1 02

Priority Area 13. CAA National Emissions Inventory (NEI) Reporting 36
A1 . Eliminate Duplicative NEI Reporting 45
A12. Streamline NEI Reporting 49

P rj ority Area 1 4. CAA Inspection & Maintenance (I/M) Program Reporting 38
A10. Reduce Reporting Frequency of the l/M Semi-Annual Report 49
A21 . Reduce Data Elements Required in I/M Reporting 53

P rj ority Area 1 5. Safe Drinking Water Information System (SDWIS) 40
W1 . Streamline Reporting In or Related to SDWIS 88
W3. Streamline Significant Noncompliance Reporting in SDWIS 89
W27. Improve Data Sharing with SDWIS 103
W31 . Use SDWIS for All Water-Related Reporting 1 07
W33. Use SDWIS to Collect Sanitary Survey Plans Data 1 08
W34. Use SDWIS for Operator Certification Program Reporting 1 09
J3 rj °-rJty Area I 6 -. Qy L3rt?r.'y.
G8. Reduce Reporting Frequency for Smaler Grants and Programs 75

: Recrmenc*at'rs 4
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Executive Summary
The U.S. Environmental Protection Agency (EPA) strives to maintain a clear line of sight between Agency
goals and day-to-day activities while fulfilling its mission of protecting human health and the environment. At
the same time, EPA strives to use resources as efficiently as possible and work with the states so they are
able to do the same. While eliminating low-value reporting burden may not sound like a glamorous job, it is
vital to improving federal and state effectiveness and hence environmental protection.

In an effort to address state concerns over escalating reporting requirements, EPA and the Environmental
Council of the States (EGOS) launched a joint Burden Reduction Initiative (hereinafter, Initiative) in October
2006. This Initiative aims to reduce states' low-value, high-burden reporting requirements, thus conserving
both states' and EPA's valuable resources while maintaining a commitment to environmental protection.

EPA has been steadily working to address the states' recommendations since the Initiative began. In
summer 2008, EPA focused on:
1. Addressing 16 priority areas (encompassing 45 unique recommendations; roughly 130
recommendations if duplicates are counted) identified by the states in summer 2007,
2. Increasing the Initiative's transparency and clarity, and
3. Creating tools for incorporating burden reduction into EPA's standard operating procedures.

While some state recommendations have already been fully implemented, EPA continues to work on others.
EPA has addressed the recommendations in three of the 16 priority areas, and partially addressed each of
the remaining thirteen areas. The three completed priority areas pertain to:
1. Regional reporting requirements related to stationary sources permitting - Region 4 agreed to
eliminate a report on Prevention of Significant Deterioration/ New Source Review (PSD/NSR)
determinations that result in "non-applicable" determinations. Region 4 also agreed to eliminate a
report that documents when a state has made no Clean Air Act Section 112(g) determinations in a
given year. See Priority Area 2 for more details.
2. The Enforcement and Compliance History Online (ECHO) Web site - EPA improved the ease
with which states and other ECHO users can correct errors on the site. The new "report error" link
found on most pages of the site reduces the time states must spend verifying data. See Priority Area
8 for more details.
3. Disadvantaged Business Enterprise (DBE) utilization reporting for some grants and
assistance agreements - Some grants included a requirement to report on DBE utilization
quarterly. EPA reduced the requirement to a semi-annual reporting frequency, at most. See Priority
Area 11 for more details.

Nineteen of 45 priority recommendations have been "started but not finished." The majority of these
recommendations continue to be addressed through four initiatives:

1. New grant reporting policy - Five grants-related burden reduction recommendations are classified
as "started but not finished." They will be addressed through an EPA-wide standardized grant
reporting policy. Among other things, the policy will require progress reports no more frequently than
twice per year, except for poor performers or where Regions and states have otherwise agreed. In
some cases, reports will be required only once per year. EPA anticipates that the policy will be
finalized and circulated in fall 2008.

2. National Pollutant Discharge Elimination System (NPDES) reporting updates - Six burden
reduction recommendations relate to reporting under the NPDES program. EPA has developed a
more robust data system called the Integrated Compliance Information System for NPDES (ICIS-
NPDES). Currently, EPA is drafting a new rule to identify essential information EPA needs to receive
from NPDES-authorized states and tribes via ICIS-NPDES to effectively manage the program.
Depending on the information required under the rule, current reports like the NPDES Annual
Noncompliance Report may be eliminated by the rule. Currently, the Agency plans to complete the
rule in the last quarter of calendar year 2009.
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3. Safe Drinking Water Information System (SDWIS) improvements - Four recommendations
associated with SDWIS have been and will continue to be addressed by a number of state-EPA work
groups (SDWIS Data Sharing Committee, SDWIS Data Management Steering Committee,
Association of State Drinking Water Administrators work group, etc.). Since 2006, these work
groups have made significant improvements to SDWIS, which has streamlined data calculation, data
queries, and other data extraction. States help define future improvements and set priorities for
further modernization efforts.

4. Clean Water Act Section 303(d)/305(b) reporting revisions - Only one recommendation concerns
Section 303(d)/305(b) integrated reporting (i.e., reduce the frequency and detail of reporting), but
twenty-two states submitted this recommendation. EPA maintains a state-federal work group - in
collaboration with the Association of State and Interstate Water Pollution Control Administrators
(ASIWPCA) -that focuses on integrated reporting. The group is working to reduce reporting burden
and increase flexibility, among other things. EPA has developed a new guidance memo for the 2010
reporting cycle in response to the recommendations submitted by this work group. It will introduce
more flexibility into the reporting process. This memo will be finalized and circulated in the last
quarter of calendar year 2008.

This progress report portrays the complexity of the work EPA and the states are undertaking. In the coming
years, EPA will continue to work with states in a variety of forums to make burden reduction a part of
"business as usual."

EPA and EGOS have already formed a Burden Reduction work group. This group has helped to shape the
Initiative and this report. It will continue to guide the Initiative in coming years. In addition, EPA has formed
a new Burden Reduction Task Force that is composed of several EPA national and Regional offices with
reporting responsibilities. Approximately 100 of the 230 recommendations submitted in 2006 are not
addressed in this report. That is because this report focuses on the roughly 130 recommendations that fall
within the 16 priority areas. One of the first jobs for the Task Force will be to work with EGOS to determine
how the remaining recommendations should be managed. (All recommendations, including those that are
not part of a priority area, are listed in the Appendix to allow easy access to a full list of state
recommendations.) EPA has launched a new Burden Reduction Web site that will provide easily accessible
updates about these recommendations and other aspects of the Initiative.
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1.0  Introduction
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1.1    Background and Purpose
In an effort to address state concerns over escalating
reporting requirements accompanied by decreases in federal
funding, the U.S. Environmental Protection Agency (EPA)
and the Environmental Council of the States (EGOS)
launched the Burden Reduction Initiative in October 2006.
This Initiative aims to reduce states' low-value, high-burden
reporting requirements, thus conserving both states' and
EPA's valuable resources while maintaining a commitment to
protecting human health and the environment.

Each of the 50 states was asked to identify their top five
reporting requirements for potential streamlining or
elimination. Thirty-nine states responded, recommending
more than 200 ways to reduce reporting frequency and level
of detail, increase electronic data entry, and to the extent
possible, standardize regional differences in reporting
requirements.

EPA has been steadily working to address the states'
recommendations since the Initiative began. The Agency
previously provided updates in summer 2007 and spring
2008.  In summer 2008, EPA focused on:
    1.   Addressing 16 priority areas identified by the states
        in summer 2007,
    2.   Increasing the  Initiative's transparency and clarity,
        and
    3.   Creating tools for incorporating burden reduction into
        EPA's standard operating procedures.

This introductory section addresses each of these three
efforts.  It also provides an overview of EPA's progress and
explains how to  use this report. EPA will report on the
progress of each priority area listed herein at the EGOS
Annual Meeting  in September 2008.
1.2   16 Priority Areas

In summer 2007, the states identified 16 priority areas on
which to focus. These 16 priority areas encompass 45
unique recommendations (approximately 130
recommendations when duplicates are counted).

The priority areas bundle together similar recommendations.
For example, Priority Area 2 groups two recommendations
that pertain to stationary sources of air pollution.

The table that follows illustrates which recommendations fall
under each priority area.
tate recommendations from.
      Alabama
      Arizona
      Arkansas
      Colorado
      Connecticut
      Delaware
      Florida
      Hawaii
      Iowa
      Illinois
      Indiana
      Kansas
      Kentucky
      Maine
      Maryland
      Massachusetts
      Michigan
      Minnesota
      Mississippi
      Montana
      Nebraska
      Nevada
      New Hampshire
      New Jersey
      New York
      North Dakota
      Ohio
      Oklahoma
      Oregon
      Pennsylvania
      Rhode Island
      South Carolina
      South Dakota
      Tennessee
      Texas
      Utah
      Vermont
      Virginia
      Wisconsin
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16 Priority Areas & State Recommendations Related to Each
Priority Area
1^_ Regional Clean Air Act (CAA)
Section 105 Grant Reporting
2._ CAA Prevention of Significant
Deterioration/ New Source Review
(PSD/NSR) and Section 11 2(g)
Reporting
3. Clean Water Act (CWA) Section
303(d) and 305(b) Integrated
Reports
4. CWA Non-Point Source Report

5._ Compliance Reporting Under the
National Pollutant Discharge
Elimination System (NPDES)
6._ Integrated Compliance Information
System/ Permit Compliance System
(ICIS/PCS) Requirements
~L_ Duplicate Enforcement Reporting
8. Enforcement and Compliance
History Online (ECHO) Web
Interface
£._ Performance Partnership Grant
(PPG)/ PPA Categorical Grant
Reporting
Related Recommendations
A2.
A6.
A7.
W16.
W30.
W22.
W24.
E4-
E12.
E26.
W4.
W23.
E1.
§2.
E3.
E5-
§6.
E14.
E16.
E17.
E24.
E27.
E29.
E7.
E10.

G5.
G6.
G9.
Reduce Reporting Frequency for CAA Section 105
Grant Reporting
Eliminate Report on "No Determinations" Under CAA
Section 112(g)
Eliminate Report on PSD/NSR Non-Applicability
Determinations
Keep CWA Sections 303(d) and 305(b) Reports
Separate
Reduce Frequency of 303(d) and 305(b) Integrated
Reports
Streamline Non-Point Source Report
Harmonize Water Reports with Different Reporting
Periods and Frequencies
Eliminate NPDES Annual Noncompliance Report
(ANCR)
Eliminate NPDES Semi-Annual Statistical Summary
Reduce Frequency of NPDES Quarterly Non-
Compliance Report (QNCR)
Eliminate Quarterly Electronic Permit Issuing
Forecasting Tool (E-PIFT) Report
Reduce Reporting on Draft Major and Minor NPDES
Permits
Reduce ICIS Data Requirements
Reduce Data Elements in ICIS' Required Integrated
Compliance Information System Data Elements
(RIDE)
Streamline Data Requirements in NetDMR for NPDES
Discharge Monitoring Reports (DMR)
Eliminate Reporting Enforcement and Compliance
Assurance Priorities (RECAP) Report
Eliminate or Reduce Frequency of CAA, CWA, and
Resource Conservation and Recovery Act (RCRA)
Quarterly Watch Lists
Eliminate Annual Monitoring Report under CAA
Section 105
Eliminate Requirement to Submit NPDES Enforcement
Documents
Eliminate Significant Industrial User(SIU) Semi-
Annual and Annual Reports
Use Performance Partnership Agreement (PPA) for
Enforcement Reporting
Eliminate the Annual Public Water System (PWS)
Compliance Report
Consider State Notices of Violation (NOVs) to be
Formal Actions
Improve Data Management in ECHO
Eliminate Reports that can be Retrieved from PCS or
ECHO
Eliminate Reporting on State-Based or Other
Programs Not Federally Funded
Reduce PPA/PPG Reporting Frequency
Streamline PPA/PPG Reporting Requirements
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10.
11.
12.
13.
14.
15.
16.
CWA Section 319 Grant Reporting
Disadvantaged Business Enterprise
(DBE) Utilization Reporting
Underground Injection Control (UIC)
Reports
CAA National Emissions Inventory
(NEI) reporting
CAA Inspection & Maintenance (I/M)
Program Reporting
Safe Drinking Water Information
System (SDWIS)
Quarterly Grant Reports
W15.
W18.
W36.
G7.
W17.
W26.
A1.
A12.
A10.
A21.
W1.
W3.
W27.
W31.
W33.
W34.
G8.
Eliminate Annual Summary of CWA Sections 106 and
319 Quarterly Reports
Modify CWA Section 319 Grant Reporting and
Tracking System (CRTS)
Reduce Frequency of CWA Section 319 Reporting
Reduce Reporting Frequency on Disadvantaged
Business Enterprise (DBE) Utilization
Streamline UIC Reports
Provide Funds or Reduce Requirements for Class V
UIC Program
Eliminate duplicative NEI reporting
Streamline NEI reporting
Reduce Reporting Frequency of the I/M Semi-Annual
Report
Reduce Data Elements Required in I/M Reporting
Streamline Reporting In or Related to SDWIS
Streamline Significant Noncompliance Reporting in
SDWIS
Improve Data Sharing with SDWIS
Use SDWIS for All Water-Related Reporting
Use SDWIS to Collect Sanitary Survey Plans Data
Use SDWIS for Operator Certification Program
Reporting
Reduce Reporting Frequency for Smaller Grants and
Programs
1.3 Improving Transparency and Clarity

Earlier this year, the states asked that EPA increase the Burden Reduction Initiative's transparency. The
Agency responded with a number of steps:

• EPA created a Burden Reduction Web site that serves as an analog to this report. Once fully
populated, it will offer a number of interactive features not available in this report. Users will be able
to:
o Sort recommendations by 1) the environmental media they pertain to, 2) the states that
made the recommendations, and 3) the priority areas.
o Access the original state submissions.
o Where available, read documentation of the steps EPA has taken to address the 16 priority
areas.

• EGOS and EPA formed a Burden Reduction Subgroup (Subgroup) to discuss the issues addressed
in this report, as well as how the information is presented. The Subgroup will continue to meet after
this report is released in order to determine next steps.

• This progress report has changed from previous progress reports in two ways, each of which is
intended to increase transparency. The report:
o Provides timelines for the steps EPA has taken and will take to address each
recommendation.
o Summarizes each state's recommendations in more detail to provide clarity (see the
Appendix). In many cases, the states' original words are provided. (The Appendix
summarizes the states' comments if they are quite lengthy, but the Web site provides the full
text of original submissions.)
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In addition to improving transparency, the Agency has tried to clarify EPA's progress. This past spring,
states told EPA that the number of categories used to describe progress (i.e., status categories) needed to
be expanded because, in previous progress reports, a number of recommendations were classified as
"Implemented" when in fact there were differences in their progress. For example, one "Implemented"
recommendation may have fully met a state's recommendation while another "Implemented"
recommendation may have only partly met the states' suggestions. The states recommended that EPA use
different status categories in such instances. Thus, with input from the Subgroup, seven status categories
were defined for this report (e.g., "Implemented," "Implemented In Part," "Started But Not Finished"). Each
category is defined in Section 1.6 below.

1.4 Tools for Making Burden Reduction Part of EPA's Standard Business

An important part of EPA's efforts this summer has been looking toward the future and determining how
burden reduction can be more integrated into EPA's standard operating procedures. EPA strives to maintain
a clear line of sight between agency goals and day-to-day activities while fulfilling its mission of protecting
human health and the environment. At the same time, EPA strives to use resources as efficiently as
possible and work with the states so they are able to efficiently use their resources. While eliminating low-
value reporting burden may not sound like a glamorous job, it is vital to improving federal and state
effectiveness and hence environmental protection.

EPA has taken two steps to institutionalize reporting burden:

1. EPA Burden Reduction Task Force - In August 2008, the EPA Burden Reduction Task Force held
its first meeting. The Task Force is charged with determining the scope of the continuing Burden
Reduction Initiative and identifying, prioritizing, and addressing opportunities for burden reduction. It
is composed of members from several EPA offices with reporting responsibilities:
• Office of Congressional and Intergovernmental Relations;
• Office of Enforcement and Compliance Assurance;
• Office of Environmental Information;
• Office of Grants and Debarment;
• Office of Policy, Economics, and Innovation;
• Office of the Chief Financial Officer; and
• Regional representatives.

The Task Force will work with the ECOS-EPA Burden Reduction Subgroup to ensure state input into
future efforts. One of the first jobs for the Task Force and Subgroup will be to determine how the
remaining recommendations - those that do not fall within a priority area and therefore are not
addressed in this report - will be managed in the future. (All recommendations, including those that
are not part of a priority area, are listed in the Appendix.)

2. Web-Based Burden Reduction Nominations - In the near future, EPA's Burden Reduction Web
site will include a mechanism for nominating opportunities for burden reduction. Details about how to
nominate an idea and the process the Agency will use to assess ideas will be decided by the Task
Force.
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1.5 Overview of Progress

EPA has addressed three of the 16 priority areas, and many individual recommendations under other priority
areas. The three completed areas are:
1. Regional reporting requirements related to stationary sources permitting - Region 4 agreed to
eliminate a report on Prevention of Significant Deterioration/ New Source Review (PSD/NSR)
determinations that result in "non-applicable" determinations. Region 4 also agreed to eliminate a
report that documents when a state has made no Clean Air Act Section 112(g) determinations in a
given year. See Priority Area 2 for more details.
2. The Enforcement and Compliance History Online (ECHO) Web site - EPA improved the ease
with which states and other ECHO users can correct errors on the site. The new "report error" link
found on most pages of the site reduces the time states must spend verifying data. See Priority Area
8 for more details.
3. Disadvantaged Business Enterprise (DBE) utilization reporting for some grants and
assistance agreements - Some grants included a requirement to report on DBE utilization
quarterly. EPA reduced the requirement to a semi-annual reporting frequency, at most. See Priority
Area 11 for more details.

The following tables provide an overview of progress on each recommendation. The second table focuses
on just those recommendations that are classified as "Started But Not Finished." (See Section 1.6 for
definitions of status categories, such as "Implemented" and "Implemented In Part.") It demonstrates that
many of the recommendations with this status category are being met by Agency-wide initiatives.
Status
Implemented
Implemented In Part
Started But Not Finished
Will Not Be Implemented
Withdrawn
#of Recommendations
19
How EPA Will Address the Recommendations That Are "Started But Not Finished"
Recommendation Codes
E1, E2, E3, E4, E12, W23
A2, G6, G8, W18, W36
W1 , W3, W27, W34
W30
W17
A12
E17
# of Recommendations
6
5
4
1
1
1
1
Will Be Addressed By
ICIS-NPDES rulemaking
EPA-wide grants policy
SDWIS
303(d)/305(b) work group
New DIG database
Emissions Inventory System
Region
As shown in the tables, four Agency-wide initiatives are meeting 16 of the 19 recommendations for which
EPA has started work but not finished it. The initiatives are:

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many cases, reports will be required only once per year. EPA anticipates that the policy will be
finalized and circulated in fall 2008.

3. Safe Drinking Water Information System (SDWIS) improvements - Four recommendations
associated with SDWIS have been and will continue to be addressed by a number of state-EPA work
groups (SDWIS Data Sharing Committee, SDWIS Data Management Steering Committee,
Association of State Drinking Water Administrators workgroup, etc.). Since 2006, these work
groups have made significant improvements to SDWIS, which has streamlined data calculation, data
queries, and other data extraction. States help define future improvements and set priorities for
further modernization efforts.

Approximately 100 of the 230 recommendations submitted in 2006 are not addressed in this report. That is
because this report focuses on the roughly 130 recommendations that fall within the 16 priority areas. The
remaining 100 recommendations will be referred to the EPA Burden Reduction Task Force. One of the first
jobs for the Task Force will be to work with the Subgroup to determine how the remaining recommendations
should be managed in the future. (All recommendations, including those that are not part of a priority area,
are listed in the Appendix.)

1.6 How To Use This Report

This report provides information on each of the 16 priority areas as well as each of the underlying
recommendations. Descriptions of the priority areas can be found in Section 2. Most readers will likely want
to focus their attention on Section 2 since it gives a good overview of each state recommendation and EPA's
response. For each of the 16 priority areas, the following information is provided:
. A summary discussion of the issue;
. The recommendations that underlie the priority area;
. How EPA has addressed these recommendations;
. Which states submitted the recommendations;
. The current status of each recommendation (described below):
. The type of resolution associated with the recommendation(s) (described below): and
. The timelines and documentation associated with the resolution.

Both internal and external hyperlinks are provided throughout the report, as evidenced in this section. The
internal hyperlinks allow the reader to jump between a priority area and the recommendations that fall under
that priority. Hyperlinks appear as blue, underlined text. Those who are reading a hard copy of the report

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should interpret the blue, underlined text as cues to where they can find more information. The table of
contents can guide hard-copy readers.

Readers will find details on the 45 recommendations that fall under the priority areas in the Appendix. Also
in the Appendix are those recommendations that did not fall within a priority area. These "non-prioritized"
recommendations are not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007. But, each one is listed in the Appendix to ensure easy access to
the full list of states' submissions.

For each recommendation that falls under a priority area, the Appendix includes:
. The related priority area;
. The current status category (described below):
. The applicable trends (described below):
. The states' original input from October 2006; and
. EPA's response(s) to the recommendation.

Also, the Appendix lists some recommendations that were in previous progress reports but have been
deleted from this report, and some recommendations that were not in previous progress reports but have
been added to this report. A note is provided explaining each deletion and addition.

Each recommendation is listed in order of the codes applied to the recommendations in early 2008 during
development of the spring 2008 progress report. First, those recommendations related to the Office of Air
and Radiation (recommendations coded A#) are listed. Then, those related to enforcement programs
(recommendations with codes E#), followed by those related to grants or other cross-cutting programs
(coded G#) and those related to pollution prevention programs (coded P#). Recommendations related to
solid waste and emergency response programs (coded SVW) come next, and finally those related to water
programs (coded VW) are listed.

Throughout Section 2 and the Appendix, status, resolution, and trend categories are listed. The rest of this
sub-section provides definitions of each.
Status
Recommendations have been assigned status categories that describe their position in the resolution
process. These categories were developed with input from the ECOS-EPA Burden Reduction Subgroup
after the states recommended that EPA provide more clarity when reporting on Agency progress. The
categories are defined in the following table. They have been assigned a color code that is used throughout
the report. Please note that some of these categories were not needed for this report:
Status Category
Implemented
Implemented In Part
Started But Not Finished
Not Started But Will Be
Implemented
Will Not Be Implemented
Withdrawn
More Information Needed
Color Code

^^^

Definition
EPA met the states' recommendation.
EPA has concluded its work on the recommendation and has
partly met the states' recommendation.
EPA has begun to address the recommendation but has not
completed its work.
EPA intends to address the recommendation in some fashion
but has not begun working on it. (This category was not
applied to any of the recommendations in this report.)
EPA has determined that this recommendation will not be
implemented.
After further discussion with the state that made the
recommendation, the state decided to withdraw it.
Before EPA can determine how the recommendation will be
addressed, more information is needed. (This category was
not applied to any of the recommendations in this report.)
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Type of Resolution
The "Types of Resolution" categories indicate the ways in which the recommendations must be addressed.
The three possible types of resolution are:
. Policy - EPA must change a policy to achieve the resolution.
. Regulatory - EPA must change a regulation to achieve the resolution.
. Statutory - EPA must recommend to Congress a statutory amendment or new statute to achieve the
resolution.
Trends
Upon examination of the recommendations, several common trends emerged. These trends are:
. Reduce reporting frequency
. Change reporting deadlines
. Align Regional reporting requirements with national requirements
. Eliminate redundant reporting
. Streamline databases
. Eliminate low-value data requirements
. Additional resources are needed for additional reporting requirements

After reviewing each of the recommendations that fall under a priority area, EPA found that the trends
appeared with the following frequencies:
Number of Times a Trend Related to a Recommendation in a Priority Area
30
25 Y
20
15-
10
5-
0
The newly formed EPA Burden Reduction Task Force will review these trends as they deliberate on methods
for institutionalizing burden reduction in EPA's business practices.
Page 11

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2.0  Priority Areas
       Page 12

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Priority Area 1 » Regional Clean Air Act (CAA) Section 105 Grant Reporting
.tate recommendations from.
JA.
Alabama
Kentucky
South Carolina
Clean Air Act (CAA) Section 105 continuing environmental
program grants are awarded to state, tribal, and local air
pollution control agencies. These grants are used to develop
and implement programs for the prevention and control of air
pollution, or for the implementation of national primary and
secondary ambient air quality standards. Three states -
Alabama, Kentucky, and South Carolina - made several
recommendations related to Section 105 grant reporting. All
three states are within EPA's Region 4; therefore, Region 4
responded to the states' recommendations.

Further details on Region 4's response are under
Recommendation A2. In general, Region 4 eliminated certain
Section 105 grant reports but did not agree to reduce all
reporting to an annual frequency, as requested by Alabama.
Instead, Region 4 offered to discuss eliminating specific
quarterly reports required in Alabama's assistance agreement on a case-by-case basis.

On a national scale, EPA's Office of Grants and Debarment (OGD) is developing a standardized grant
reporting policy. This policy will apply to Section 105 grants, as well as all other EPA grants. Among other
things, the policy will set a standard grant reporting frequency of no greater than twice per year, except for
poor performers or where Regions and states have otherwise agreed. The draft policy has been circulated
for review by members of the Environmental Council of the States' State Grants Workgroup. A final version
is expected in fall 2008. The draft policy recommends reducing Section 105 reporting to an annual
frequency as requested by Alabama. See Priority Area 16 for more information.

Region 4 has "Implemented" each of the recommendations made by Alabama, Kentucky, and South
Carolina, except for Alabama's request to reduce all quarterly reports to an annual frequency. At a minimum,
this reporting frequency will be reduced by the soon-to-be-released grant reporting policy. Thus, this priority
area is classified as "Started But Not Finished" because OGD's grant reporting policy is not complete.
Timeline / Documentation
• 07/17/2007 - 07/18/2007 - At a meeting of the
Partnership and Performance Workgroup of the
Environmental Council of the States (EGOS), states
recommended that grant progress reports should be
required no more frequently than semi-annually unless
there is documented need for more frequent reporting.

• FY2007 - Region 4 confirmed that grant reports need to
be submitted only once and to EPA program personnel.

• FY2007 - Region 4 confirmed that annual narrative
summaries are required only when grant commitments
are unmet or significantly delayed.

• FY2007 - Region 4's mobile sources quarterly reporting requirement was removed from all state and
local Section 105 assistance agreements.
responses
Nationwide Resolution
A2

Status
Started But Not Finished
(grant reporting policy)
Regional Resolution(s)
A2

Status
Implemented In Part
Type of Resolution: Policy
Page 13

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07/29/2008 - OGD distributed the draft grant reporting policy to the co-chairs of the State Grants
Workgroup, a subgroup of the EGOS Partnership and Performance Workgroup.

Fall 2008 - OGD plans to distribute and implement the final grant reporting policy.

09/30/2009 - OGD expects to confirm implementation by reviewing a random sample of grant awards to
ensure the reporting terms and conditions adhere to the policy's maximum of semiannual reporting
(except in the case of poor performers or where otherwise agreed).
                                        Page 14

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Priority Area 2 » Clean Air Act (CAA) Prevention of Significant Deterioration/
New Source Review (PSD/NSR) and Section 112(g) Reporting
aie recommenaauons rrom.
Kentucky
South Carolina
Under the Clean Air Act (CAA) Amendments of 1990, EPA is
required to regulate large, or "major," industrial facilities that
emit one or more of 188 listed hazardous air pollutants (air
toxics). Air toxics are those pollutants that are known or
suspected of causing cancer or other serious health effects,
such as developmental effects or birth defects.

Two states - Kentucky and South Carolina - recommended
two changes pertaining to CAA requirements for stationary
sources:
1. Eliminate the requirement to submit a report to EPA if
no Section 112(g) determinations are made in a given
year. It is redundant since states are required to enter
data into the 112(g) clearinghouse.
2. Eliminate the requirement to report Prevention of
Significant Deterioration/ New Source Review
(PSD/NSR) determinations that result in a non-applicability determination.

The CAA Section 112(g) provision is designed to ensure that emissions of toxic air pollutants do not increase
if a facility is constructed or reconstructed before EPA issues a nationally applicable maximum achievable
control technology (MACT) standard for a particular category of sources or facilities. Specifically, section
112(g) requires that sources obtain a case-by-case MACT standard that shall not be less stringent that the
emission control which is achieved in practice by the best controlled similar source. In effect, the section
112(g) provision is a transitional measure, as it ensures that facilities that construct or reconstruct prior to
EPA's issuance of a national MACT emission standard must control their hazardous air pollutant emissions.

Prevention of Significant Deterioration (PSD) applies to new major sources or major modifications at existing
sources. It requires facilities to install Best Available Control Technology (BACT); conduct an air quality
analysis: conduct an additional impacts analysis: and ensure that the public is involved in any decision to
permit increased air pollution.

Both Kentucky and South Carolina are within EPA's Region 4; therefore, Region 4 responded to the states'
recommendations. Region 4 agreed to both of the states' recommendations. You may read the details on
Region 4's response under Recommendations A6 and A7.
08/24/2007 - Region 4 eliminated "no determinations"
reporting under 112(g). It was eliminated for all state and
local air agencies in the Region, and all twenty-four
agencies were notified.

FY2007 - Region 4 has not required South Carolina to
report PSD/NSR non-applicability for a number of years.

04/02/2008 - Region 4 and Kentucky agreed via email to
eliminate the PSD/NSR non-applicability. Instead,
Kentucky will follow South Carolina's process of
announcing non-applicability in their public notices.
responses
Regional Resolution(s)
A6
A7

Status
Implemented
Implemented
Type of Resolution: Policy
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Priority Area 3 » Clean Water Act (CWA) Section 303(d) and 305(b) Integrated
Reports
Sections 305(b) and 314 of the Clean Water Act (CWA)
require states, territories, and authorized tribes to provide
biennial reports to EPA on the condition of waters within their
boundaries. EPA regulations at 40 CFR 130.7 require states
to provide biennial submissions of impaired waters lists. EPA
provides guidance on these reports in a way that supports the
Agency's strategy for achieving a broad-scale, national
inventory of water quality conditions. The guidance is from
EPA to states, territories, authorized tribes, and interstate
commissions ("jurisdictions") to help states prepare and
submit Section 305(b) reports to EPA. Use of the integrated
report (IR) format provides jurisdictions a recommended
reporting format and suggested content to be used in
developing a single document that integrates the reporting
requirements of Sections 303(d), 305(b), and 314. This format
allows jurisdictions to report on the water quality standards
attained for all waters, document the availability of data and
information for each segment, identify certain trends in water
quality conditions, and set priorities for protecting and
restoring the health of the nation's aquatic resources.

Twenty-two states recommended burden reduction relief
associated with preparing biennial integrated reports of their
water quality status. In particular, the requests focused on
changing the frequency of integrated reporting. Most states
recommended reporting every four or five years as opposed to
the current two years.

While EPA will not reduce reporting frequency, as
recommended, the Agency is working with the states to
streamline the reporting process. Thanks to a collaborative
effort in 2007 and 2008, revised reporting requirements will
provide states with the flexibility that they seek, without
jeopardizing the quality, timeliness, and accuracy of the
required water quality information. More information about
these efforts is available under Recommendation W30. These
revised requirements will be communicated in an integrated
reporting memorandum, which the Office of Water expects to
finalize in the last quarter of calendar year 2008.
tate recommendations from.
Arkansas
Colorado
Delaware
Hawaii
Illinois
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Montana
Nevada
New York
Ohio
Oklahoma
South Dakota
Tennessee
Utah
Vermont
Virginia
Wisconsin
EPA will not completely eliminate two-year reporting cycles,
as the states requested, for several reasons. The 305(b) and 303(d) data reported by the states is an
essential part of EPA's Clean Water Act responsibilities, and is reflected in the Agency's Program
Assessment Rating Tool (PART) and Strategic Plan measures. This data is key to informing a wide range of
stakeholders about the status and progress of protecting and restoring the health of the nation's waters, and
for identifying where management actions and total maximum daily load (TMDL) calculations need to be
developed and implemented. The impact of lengthening this cycle, as the states recommended, and thus
forgoing data reporting in most years, would present significant challenges to demonstrating progress in
protecting water quality, informing the public, and justifying the use of state and federal resources.
Page 16

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Timeline / Documentation
Responses
Nationwide Resolution
W30

Status
Started But
Not Finished
Regional Resolution(s)
W16

/
Status
Withdrawn
Type of Resolution: Policy
8/12/2005: Federal Register notice announcing the
availability of the 2006 Integrated Report Guidance.
10/12/2006: Memorandum to release the 2008 Integrated
Report Guidance.
03/2007- Mid-year Association of State and Interstate
Water Pollution Control Administrators (ASIWPCA)
Meeting: EPA and states discussed the integrated report
issue.
04/2007 - A workgroup was chartered.
06/2007 - Issue white paper drafted.
08/26/2007 - 08/28/2007 -Annual ASIWPCA meeting, Sturgeon Bay, Wl. Discussion of white paper.
o The workgroup solicited comments on the most viable options from state and EPA regional
reviewers.
03/02/2008 - 03/04/2008 - Mid-year ASIWPCA Meeting, Arlington, VA. Further discussion.
03/25/2008 - ASIWPCA completed a project to evaluate several burden reduction options for 303(d) and
305(b) reporting, and shared their conclusions and recommendations in a letter from Harry Stewart
(President of ASIWPCA) to EPA's Assistant Administrator for the Office of Water, Ben Grumbles. To
access Mr. Stewart's letter, please see http://www.asiwpca.org/TaskForces/MSATF.htm and open
"ASIWPCA on Integrated Reporting" from the "Latest Documents of Interest" drop-down menu.
Summer 2008 - Development of 2010 Integrated Report Memorandum
o As the Office of Water's (OW) Assessment and Watershed Protection Division (AWPD) develops the
2010 Integrated Reporting Memorandum, which provides clarification to states on specific listing and
reporting issues, a number of these recommendations are being considered.
o OWwill review the results of the pilot studies tested during the 2008 IR/303(d)/305(b) cycle and
incorporate results in OWs clarification memo for the 2010 reporting cycle.
08/18/2008 - 08/20/2008 -Annual ASIWPCA meeting, Providence, Rl.
Fall 2008 - Draft of 2010 IR Memorandum anticipated to be sent for stakeholder review.
Last Quarter of Calendar Year 2008 -Completion of the 2010 IR Memorandum expected.
Page 17

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Priority Area 4 » CWA Nonpoint Source Report

aie recommendations rrom.
Congress amended the Clean Water Act (CWA) in 1987 to
establish the Section 319 Nonpoint Source Management
Program. Under Section 319, state, territories, and tribes
receive grants to support a wide variety of activities including
technical assistance, financial assistance, education, training,
technology transfer, demonstration projects, and monitoring to
assess the success of specific nonpoint source
implementation projects. More information on the allocation of
these grants is available on EPA's Nonpoint Source Pollution
Web site. Section 319 grant funds are eligible for inclusion in
state Performance Partnership Grants (PPG).

Iowa, Massachusetts, New Jersey, and Oklahoma expressed
concerns about various elements of CWA Section 319 grant
reporting, including report length, reporting period, report
duplication, and varying report deadlines.

As stated in EPA's recent FY2009 National Program Guidance
for the Office of Water, EPA and the states need to continue to effectively implement and better integrate
programs established under the CWA to protect, improve, and restore water quality on a watershed basis.
Regions have the flexibility to emphasize various parts of core national programs and modify targets to meet
EPA Region and state needs and conditions. Among the key tasks identified in the Program Guidance is the
goal to implement practices to reduce pollution from all nonpoint sources. Many of the details of report
frequency, length, and deadline are established at a Regional level.

Region 6 worked with Oklahoma to streamline and shorten its annual report. Region 7 and Iowa negotiated
new terms for the FY2008-2009 PPG for more uniformity in reporting timelines. Region 1 clarified that
nonpoint source data has been requested more frequently in the past but now is only required on an annual
basis. Similar to Region 7, Region 2 worked with the State of New Jersey to find opportunities to streamline
reporting requirements and deadlines. More detail on these regional responses can be viewed in further
detail at Recommendation W22 and Recommendation W24. Additional information on Section 319 grant
reporting is available in Priority Area 10.
Iowa
Massachusetts
New Jersey
Oklahoma
Timeline / Documentation
Type of Resolution: Policy
04/24/2006 - FY 2007 National Water Program Guidance
was released.

FY 2007 - Region 6 clarified for its states that only a
single report on CWA 319 program activities, due at the
end of each January, is required.

FY 2007 - Region 1 modified reporting frequency for
nonpoint source data to occur only on an annual basis.

03/29/2007 - 03/30/2007 - Region 7 met with its states at
the State Water Directors Meeting. Discussions held on possibility for negotiating PPG workplans to
align reporting deadlines and reduce Region 7-specific reports.

04/2007 - FY 2008 National Water Program Guidance was released.

04/2008 - FY 2009 National Water Program Guidance was released.
"PA Responses
Regional Resolution(s)
W22
W24

Status
Implemented
Implemented
In Part
Page 18

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04/01/2008 - Region 2 approved New Jersey's SPY 2008-2010 Performance Partnership Agreement
(PPA), which included streamlined CWA reporting requirements.
04/28/2008 - New Jersey's Commissioner of the Department of Environmental Protection approved New
Jersey's SPY 2008-2010 Performance Partnership Agreement (PPA).

Last Quarter of Calendar Year 2008 - Region 2 will meet with New Jersey as part of the PPA approval
process. Although the Region believes  most of streamlining concerns have been addressed in the PPA,
Region 2 will continue to work with NJ to identify opportunities to streamline reporting requirements.
                                        Page 19

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Priority Area 5 » Compliance Reporting Under the National Pollutant Discharge
Elimination System (NPDES)
tate recommendations from.
Illinois
Nebraska
South Carolina
Texas
Water pollution degrades surface waters making them unsafe
for drinking, fishing, swimming, and other activities. As
authorized by the Clean Water Act, the National Pollutant
Discharge Elimination System (NPDES) permit program
controls water pollution by regulating point sources that
discharge pollutants into waters of the United States.

Four states - Illinois, Nebraska, South Carolina, and Texas -
requested that NPDES reporting requirements be altered.
Three NPDES reports are currently required under NPDES
regulations (40CFR 123.45). They are:
1. The Quarterly Noncompliance Report (QNCR) - A
report on major NPDES permittees ("major" refers to
the size of a facility) in noncompliance.
2. The Semi-Annual Statistical Summary - A report on
the number of major permittees with two or more
violations of the same monthly average permit
limitation in a six-month period.
3. The Annual Noncompliance Report (ANCR) - A report on the total number of "nonmajor" permittees
that have been reviewed, the number of noncomplying nonmajor permittees, the number of
enforcement actions, and the number of permit modifications extending compliance deadlines.

The states recommended that EPA reduce the reporting frequency for the QNCR and eliminate the Semi-
Annual Statistical Summary and ANCR. EPA's Office of Enforcement and Compliance Assurance (OECA) is
responding to these recommendations by preparing a proposed rule - called the NPDES Program
Management Information Rule - that would identify the minimum NPDES data that EPA needs from NPDES
agencies (authorized states and EPA Regions) to manage the national program. The rulemaking process
would provide another opportunity for states to comment on EPA's data needs and NPDES agency
reporting.

EPA cannot now predict the data that would be identified in the proposed rule because the rulemaking
development process is still underway, but OECA expects that the rulemaking would enable EPA to collect
the necessary data to eliminate the Semi-Annual Statistical Summary and the ANCR requirements. The
ANCR could be eliminated to the extent that the replacement rule enabled EPA to effectively collect minor
permittee discharge monitoring report data using the new data system. QNCR requirements will not be
changed. (ICIS-NPDES is a database for collecting NPDES data. See Priority 6 for more information on the
database.) Currently, OECA projects the final rule will be issued in the last quarter of calendar year 2009.
Until a replacement rule becomes effective, the QNCR, Semi-Annual Statistical Summary, and ANCR remain
as regulatory requirements.

Aside from the major NPDES reports discussed above, two other reporting burdens related to NPDES fall
under this priority area.

. Minnesota, Mississippi, and South Carolina recommended that EPA streamline another database
called the Electronic Permit Issuing Forecasting Tool (E-PIFT) so that it is no longer redundant with
PCS. EPA has since eliminated E-PIFT. See Recommendation W4 for more information.

. Alabama and Kansas recommended that Regions eliminate the requirement to submit all draft major
and minor NPDES permits, including applications. Region 7 has already agreed to eliminate the
requirement to submit draft or final minor non-stormwater/ non- concentrated animal feeding
operations (CAFO) permits. Discussions between Alabama and Region 4 have not begun. See
Recommendation W23 for more information.
Page 20

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Timeline / Documentation
FY2002 - OECA began an effort to modernize PCS by
creating ICIS-NPDES.

2006 - An ICIS-NPDES Expanded Steering Committee
(ESC) was launched with involvement from the
Environmental Council of the States (EGOS), Association
of State and Interstate Water Pollution Control
Administrators (ASIWPCA), and other state
representatives. The ESC held three face-to-face
meetings and many conference calls in 2006 to discuss
the architecture and data requirements for ICIS-NPDES.

04/30/2007 - A draft ICIS-NPDES Policy Statement was
sent to the states for review. The Policy Statement
identified the minimum data reporting that EPA needed to
manage the national NPDES program.

04/22/2008 - EPA's Regulatory Policy Officer approved commencement of the ICIS-NPDES rulemaking.

As of May 2008 - 22 states, 2 tribes and 9 territories are successfully using ICIS-NPDES.

08/30/2008 - Region 6 expects to send a letter to all of the Region 6 states confirming to each that the
RECAP report is not required.

Fall/Winter 2008 - OECA expects to conduct stakeholder outreach - including outreach to the states - to
aid in writing the NPDES Program Management Information Rule to collect data in ICIS-NPDES.

Spring 2009 - EPA expects to publish the proposed NPDES Program Management Information Rule (to
collect data in ICIS-NPDES) and open a formal comment period.

Last Quarter of Calendar Year 2009 - EPA expects to publish the final NPDES Program Management
Information Rule.
EPA Responses

Nationwide Resolution
E4
E12

E26

Status
Started But Not Finished
Started But Not Finished
Will Not Be Implemented
Implemented In Part
Regional Resolution(s)
W23

Status
Started But Not Finished
Type of Resolution: Requlatorv
Page 21

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Priority Area 6 » Integrated Compliance Information System/ Permit
Compliance System (ICIS/PCS) Requirements
Water pollution degrades surface waters making them unsafe
for drinking, fishing, swimming, and other activities. As
authorized by the Clean Water Act, the National Pollutant
Discharge Elimination System (NPDES) permit program
controls water pollution by regulating point sources that
discharge pollutants into waters of the United States.

EPA collects information on implementation of the NPDES
program in a database. Since 1974, the information has been
collected in the Permit Compliance System (PCS). Since
2002, EPA has been working to modernize PCS by creating a
new data system called the Integrated Compliance
Information System for NPDES (ICIS-NPDES). The
modernization from PCS to ICIS-NPDES addresses outdated
technology and new program requirements.

Nine states recommended that EPA reduce the proposed
reporting requirements for ICIS-NPDES. The approach
EPA's Office of Enforcement and Compliance Assurance
(OECA) is taking to address the recommendations is twofold:
aie recommendations rrom.
Arizona
Iowa
Maryland
Michigan
Nevada
New Jersey
New York
Oregon
Virginia
1 . Issue a new rule - called the NPDES Program
Management Information Rule - that will define the
minimum NPDES reporting that EPA needs to
manage the national NPDES program. States will
have the opportunity to comment on EPA's proposal.
2. Streamline the ICIS-NPDES database so that data submission is easier. OECA is developing a
"batch" data transfer process (i.e., a process of moving data en masse rather than piecemeal) and
conducting an Alternative Analysis to understand if other database architectures could improve ICIS-
NPDES.

As of July 2008, 22 states, two tribes, and nine territories are successfully using ICIS-NPDES. Once final,
the new NPDES Program Management Information Rule would identify necessary data for reporting by
NPDES agencies and when those agencies (including authorized states) would be required begin reporting
pursuant to the rule. Currently, OECA projects the final rule will be issued in the last quarter of calendar year
2009. Consult the "Timeline/Documentation" section that follows for further information about the rule, batch
transfers, and the Alternative Analysis.
Timeline / Documentation
FY2002 - OECA began an effort to modernize PCS by
creating ICIS-NPDES.
2006 - An ICIS-NPDES Expanded Steering Committee
(ESC) was formed that includes representatives from the
Environmental Council of the States (EGOS) and
Association of State and Interstate Water Pollution
Control Administrators (ASIWPCA). The ESC held three
.PA Responses
Nationwide Resolution
11
12
11

Status
Started But Not Finished
Started But Not Finished
Started But Not Finished
Type of Resolution: Regulatory
Page 22

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face-to-face meetings in 2006 to discuss the architecture and data requirements for ICIS-NPDES.

10/2006 - OECA initiated the ICIS-NPDES Batch Integrated Project Team (IPT) to allow batch data
transfer into ICIS-NPDES. Participants include staff and managers from 26 states, 6 regions, OECA,
and EPA's Office of Environmental Information (OEI). IPT supported the development and testing of
batch data transfer for the NPDES Discharge Monitoring Report (DMR). (This group conducts monthly
conference calls.)

04/30/2007 - A draft ICIS-NPDES Policy Statement was sent to states and other stakeholders for
review. The Policy Statement outlined how OECA was planning to develop and implement ICIS-NPDES.

09/12/2007 - In a letter to EGOS, OECA conveyed that EPA had decided to proceed with a rulemaking
rather than a final ICIS-NPDES Policy Statement in order to collect more formalized comments on the
design of the database.
04/22/2008 - EPA's Regulatory Policy Officer approved commencement of the NPDES Program
Management Information Rule.
As of May 2008 - 22 states, 2 tribes and 9 territories are successfully using ICIS-NPDES.

Fall/Winter 2008 - OECA expects to conduct stakeholder outreach - including outreach to the states - to
aid in writing the NPDES Program Management Information Rule to collect data in ICIS-NPDES.

Spring 2009 - EPA expects to publish the proposed NPDES Program Management Information Rule (to
collect data in ICIS-NPDES) and open a formal comment period.

Last Quarter of Calendar Year 2009 - EPA expects to publish the final NPDES Program Management
Information Rule.
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Priority Area 7 » Duplicate Enforcement Reporting
A number of states recommended changes to enforcement
and compliance reporting requirements. These requirements
do not necessarily relate to one another, but they were
grouped under Priority Area 7 because they share two
common characteristics: 1) they are related to enforcement/
compliance and 2) the states have expressed concerns that
they have to submit the same information more than once.

The state recommendations under this priority area and
EPA's responses are as follows:

• E5 - Reporting Enforcement and Compliance
Assurance Priorities (RECAP) - Texas
recommended that EPA eliminate this report. Region
6 agreed.

. E6 - Quarterly Watch Lists - Nebraska and Texas
recommended eliminating the Quarterly Watch Lists
for the Clean Air Act (CAA), National Pollutant
Discharge Elimination System (NPDES), and
Resource Conservation and Recovery Act (RCRA).
After senior management discussion, EPA has
decided to not implement this recommendation. The
tate recommendations from.
p.,.
Alabama
Arizona
Colorado
Kentucky
Nebraska
North Dakota
Texas
Watch Lists are generated by EPA to reduce burden on the states as much as possible, and are a
critical tool for tracking facilities that are in violation of the CAA, CWA, and RCRA.

E14 - CAA Section 105 Annual Monitoring Report - Nebraska recommended eliminating this
report because it is already entered into EPA's Air Quality System (AQS). Region 7 agreed.

E16 - National Pollutant Discharge Elimination System (NPDES) enforcement and inspection
documents - Colorado recommended that Region 8 eliminate its requirement to submit NPDES
enforcement documents and associated correspondence as well as NPDES inspection reports.
Region 8 agreed to reduce the requirement to a subset of inspection reports (reports for majors,
concentrated animal feeding operations (CAFOs), and storm water inspection reports which have
been completed by contractors).

E17 - Significant Industrial User (SID) Semi-annual and Annual Reports - Nebraska
recommended that Region 7 eliminate its requirement that the state submit SIU reports because
Region 7 can generate them from the Integrated Compliance Information System (ICIS). Region 7
has committed to try to generate these reports itself from ICIS.

E24- Performance Partnership Agreement (PPA) Reporting - Colorado recommended that EPA
streamline its enforcement reporting by utilizing a state's PPA as its only reporting tool. Region 8
has attempted to incorporate enforcement and compliance reporting into Colorado's PPA, but the
Region cannot fully meet Colorado's recommendation. The Region has pledged to seek
opportunities for streamlined reporting on an ongoing basis.

E27 - Annual Public Water System (PWS) Report - Kentucky and North Dakota recommended
that EPA eliminate the PWS Report because the same information is available in other formats.
After senior management discussion, EPA has decided to not accept this recommendation.
Eliminating the PWS Report altogether would make it more difficult for the public to learn about the
quality of their drinking water. The Safe Drinking Water Act requires that states submit this report,
moreover, and EPA has no authority to remove a statutory requirement. EPA has taken a number of
steps to reduce states' PWS reporting burden while still meeting statutory requirements.

E29 - Notices of Violation -Alabama recommended that EPA consider state Notices of Violation
(NOVs) as formal actions given these actions can be appealed. Alabama explained that doing so
would eliminate the need to prepare reports on why the state has taken no formal action against a
violator. After senior management discussion, EPA has decided to not accept this recommendation.
Page 24

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EPA does not consider NOVs as formal enforcement actions because most state NOVs under most
state statutes are not enforceable or legally binding.
Timeline / Documentatii
Summer 2007 - Region 7 eliminated the hard-copy CAA
Section 105 Annual Monitoring Report, as Nebraska
requested, through the FY 2008-2009 Air Section 105
work plan negotiation process.

Summer 2007 - Region 8 agreed to reduce Colorado's
NPDES reporting requirement for FY2008 to a subset of
inspection reports (reports for majors, CAFOs, and storm
water inspection reports which have been completed by
contractors).

FY2007 - Region 6 informed Texas that the Reporting
Enforcement and Compliance Assurance Priorities
(RECAP) report is no longer required.

05/2008 - Region 8 and Colorado agreed to the same
subset of inspection reports (reports for majors, CAFOs,
and storm water inspection reports which have been
completed by contractors) in their FY2009 Performance
Partnership Agreement (PPA).

07/15/2008 - EPA decides to retain the Quarterly Watch
Lists and Annual PWS Report and also decided that state
NOVs would continue to not be recognized as formal
actions.

07/15/2008 - Region 7 committed to attempting to try to
generate the SIU reports from ICIS.

08/29/2008 - Region 6 sent notified all of its states that
the RECAP report is not required. (Applies to E5.)

Nationwide Resolution
E6
E27

E29

Status
Will Not Be Implemented
Will Not Be Implemented
Will Not Be Implemented
Regional Resolution(s)
E5
E14
E16
E17
E24

Status
Implemented
Implemented
Implemented In Part
Started But Not Finished
Implemented In Part
Type of Resolution: Varies bv
recommendation. All of the
recommendations require a policy
resolution, except for E27 which would
require a statutory change.
Page 25

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Priority Area 8 » Enforcement and Compliance History Online (ECHO) Web
Interface
                                                        tate recommendations from.
                                                              Maryland
The Enforcement and Compliance History Online (ECHO)
Web site provides the public with information that focuses on
facility compliance and EPA/state enforcement of
environmental regulations. ECHO provides integrated
compliance and enforcement information for approximately
800,000 regulated facilities nationwide.  It includes facilities
regulated as Clean Air Act (CAA) stationary sources, as
Clean Water Act (CWA) permitted dischargers (under the
National Pollutant Discharge Elimination System (NPDES)),
and Resource Conservation and Recovery Act (RCRA)
hazardous waste sites.

Though the data presented on ECHO were previously in the
public domain through Freedom of Information Act requests
and mainframe computer subscription, the information was
not available  in a searchable Web format until ECHO was launched in 2002. ECHO makes it much easier for
the public to obtain these data records on the  Internet.

Maryland recommended two changes to the Enforcement ECHO database:
    1.  EPA should improve data handling. States should not be expected to check EPA databases such as
       ECHO and find the things that need correcting.
   2.  Eliminate requirements to submit hard-copy enforcement and compliance reports that EPA can
       generate from ECHO or the Permit Compliance System (PCS).

In response to the first recommendation, EPA's Office of Enforcement and Compliance Assurance (OECA)
has ensured that a "Report Error" hyperlink is  available at the top of every ECHO facility report. All users of
the ECHO data - the facilities, the states, and the public - may report errors using this error-reporting
feature. EPA and state data experts receive the reports so they can correct data in their databases.  To
further ensure data quality, OECA updates ECHO on a monthly basis, performs random audits of the data,
and receives  suggestions for further improvements at echo@epa.qov. You may read more about the steps
OECA has taken to under Recommendation E7.

Region 3 addressed Maryland's second recommendation - eliminating redundant hard-copy reports - by
discussing the issue on a September 2007 conference call.  During that call, Maryland confirmed that this
recommendation was no longer a concern for them and withdrew the recommendation. Learn more under
Recommendation E10.
Timeline / Documentation
   06/2000 - The Joint EPA-state Enforcement and
   Compliance Public Access Workgroup (developed in
   partnership with The Environmental Council of the states
   (EGOS)) developed the template for the type, sources,
   and amount of data to be included within ECHO.

   11/20/2002 - ECHO was launched as a pilot site open
   for public comment.
                                                            Responses
Nationwide Resolution
E7
E10

/
Status
Implemented
Withdrawn
                                                       Type of Resolution:  Policy
   03/31/2003 - Public comment on the ECHO pilot was
   closed, and ECHO was launched as a fully operational site as OECA responded to the many comments
   submitted. EPA's Response to Comments are available online.
                                          Page 26

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03/31/2003 - ECHO'S "Report Error" feature is included in its launch.

09/2007 - Region 3 spoke with Maryland and confirmed that this recommendation was no longer a
concern for the state. Maryland withdrew the recommendation. (Applies to E10.)
                                        Page 27

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Priority Area 9 » Performance Partnership Grant (PPG)/ Performance
Partnership Agreement (PPA) Categorical Grant Reporting
tate recommendations from.
• Arizona
• Colorado
• South Dakota
• Utah
• Virginia
Many states develop Performance Partnership Agreements
(PPAs) with EPA Regions. EPA and state officials discuss
environmental conditions and program needs; agree on goals
and priorities; devise strategies to address these needs;
define responsibilities; and develop measures. States can
choose to combine some or all of their environmental
program grants in Performance Partnership Grants (PPGs).

Under traditional environmental program grants (sometimes
called "categorical" grants), states receive funds to implement
various water, air, waste, pesticides, and toxic substances
programs. Environmental program grant funds can only be
spent on activities that fall within the statutory and regulatory
boundaries of that program. However, states can choose to
combine two or more environmental program grants into a
single PPG, which allows states to support multi-media
approaches and initiatives that were difficult to fund under
traditional categorical grants.

Five states - Arizona, Colorado, South Dakota, Utah, and
Virginia - recommended three improvements to their
PPAs/PPGs:
1. Target the PPG work plan on EPA's National Performance Measures. Eliminate PPG work plan
requirements that are related to state-based or other non-federal programs.
2. Reduce reporting frequency.
3. Streamline reporting so that the application and reporting requirements for the PPA/PPG meet the
needs of all grants contained therein.

Because every PPA and PPG is a negotiated agreement between an EPA Region and a state, they vary
greatly from one to another. Thus, the first and third recommendations were addressed at the Regional
level. Read details about these resolutions under Recommendations G5 and G9.

EPA's Office of Grants and Debarment (OGD) is developing a standardized grant reporting policy that
addresses the second recommendation - reporting frequency. Among other things, the policy will set a
standard reporting frequency of no greater than twice per year, except in instances of poor performers or
where Regions and states have otherwise agreed. Many grants and assistance agreements will require a
reporting frequency of no greater than annually.

The policy applies to PPGs. If a PPG encompasses only those grants/agreements with annual reporting
requirements, then a progress report will be due annually. If the PPG encompasses some
grants/agreements with a semi-annual frequency and some with an annual frequency, then the state will
have the option to either a) report semi-annually on the entire PPG or b) report semi-annually on only those
portions of the PPG that require twice yearly reporting. The draft policy has been circulated for review by
members of the Environmental Council of the States' State Grants Workgroup. A final version is expected in
fall 2008. See Priority Area 16 for more information.
Page 28

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Timeline / Documentation
                                                        A Resoonses
Nationwide Resolution
G6

Status
Started But Not
Finished
Regional Resolution(s)
G5
G9


Status
Implemented
Implemented In
Part
                                                       Type of Resolution:  Policy
07/17/2007 - 07/18/2007 -At a meeting of the
Partnership and Performance Workgroup of the
Environmental Council of the States (EGOS), states
recommended that grant progress reports should be
required no more frequently than semi-annually unless
there is documented need for more frequent reporting.

FY2007 - Region 8 pledged to South Dakota that it will
work with the state to control unnecessary requests each
year from the various Region 8 programs and coordinate
requests.

FY2008 - Starting with this fiscal year's grant award,
Region 3 requires a semi-annual "exceptions-only" report and an annual progress report for the PPGs of
Region 3 states.

Summer/ Fall 2008 - Region 8 and Utah are negotiating the state's draft FY2009 PPA now. Utah's
recommendations plan to be addressed in this negotiation.

07/29/2008 - OGD distributed the draft grant reporting policy to the co-chairs of the State Grants
Workgroup, a subgroup of the EGOS Partnership and Performance Workgroup.

Fall 2008 - OGD plans to distribute and implement final grant reporting policy.

09/30/2009 - OGD expects to confirm implementation by reviewing a random sample of grant awards to
ensure the reporting terms and conditions adhere to the policy's maximum of semiannual reporting
(except in the case of poor performers or where otherwise agreed).
                                          Page 29

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Priority Area 10 » Clean Water Act (CWA) Section 319 Grant Reporting
Congress amended the Clean Water Act (CWA) in 1987 to
establish the Section 319 Nonpoint Source Management
Program. Under the Program, state, territories, and Tribes
receive grant money to support a wide variety of activities
including technical assistance, financial assistance,
education, training, technology transfer, demonstration
projects, and monitoring to assess the success of specific
nonpoint source implementation projects. More information on
the allocation of these grants is available online.

Several states made recommendations to modify Section 319
reporting requirements. EPA's response to these
recommendations is twofold. At the national level, EPA's
Office of Grants and Debarment (OGD) is developing an
Agency-wide grant reporting policy that will apply to CWA
Section 319 reporting, as well as all other EPA grants and
assistance agreements. Among other things, this policy will:
tate recommendations from.
Indiana
Maryland
Massachusetts
Minnesota
Montana
North Dakota
Rhode Island
1. Reduce quarterly grant progress reports to a frequency
of no greater than semi-annually, except in instances of
poor performers or where Regions and states have
otherwise agreed. In many cases, reporting frequency
will be reduced to a frequency of no greater than
annually, and OGD anticipates that an annual frequency will apply in the case of Section 319 reporting.
Since the policy is not yet final, however, it is premature to definitively say how the policy will impact
Section 319 reporting.
2. Reduce financial status reporting requirements to no more than annually.

Furthermore, the grant reporting policy addresses reporting requirements within a state's Performance
Partnership Grant (PPG), which sometimes includes Section 319 grants. If a state uses a PPG and the PPG
encompasses only those grants/agreements with annual reporting requirements, then a progress report will
be due annually. If the PPG encompasses some grants/agreements with a semi-annual frequency and
some with an annual frequency, then the state will have the option to either a) report semi-annually on the
entire PPG or b) report semi-annually on only those portions of the PPG that require twice yearly reporting.
The draft policy has been circulated for review by members of the Environmental Council of the States' State
Grants Workgroup. A final version is expected in fall 2008. See Priority Area 16 for more information.

In addition to this national response, EPA's Regions responded to the recommendations of their respective
states:

. W15 - Annual summary of quarterly Section 106 and 319 reports - Maryland recommended
eliminating annual summaries of the Section 106 and 319 quarterly reports. Region 3 clarified that
Section 106 annual summaries are no longer needed and Section 319 annual summaries were
never required.

. W18- Reporting in the Section 319 Grant Reporting and Tracking System - EPA's Grant Report
Tracking System (CRTS) provides EPA with an electronic means of accessing information on the
use of Section 319(h) funds by state agencies. The information extracted from CRTS is used to
respond to Congressional and OMB inquiries; support the Agency's nonpoint source budget request;
and provide a feedback loop on states' compliance with Agency guidance and policy. Four states -
Maryland, Massachusetts, Montana, and North Dakota - requested that EPA make it easier to
submit information into CRTS, require Section 319 implementation project reports at an annual
frequency, and provide guidance for Section 319 financial status reports (FSRs).

. W36 - Reduce Section 319 reporting frequency - Three states - Indiana, Minnesota, and Rhode
Island - recommended that EPA reduce Section 319 reporting frequency from quarterly to annually.
As mentioned above, OGD's national grant reporting policy is striving to do just that.
Page 30

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PA Responses
Nationwide Resolution
all

Status
Started But Not Finished
(grant reporting policy)
Regional Resolution(s)
W15
W18
W36

Status
Implemented
Started But Not Finished
Started But Not Finished
Type of Resolution: Policy
Summer 2007 - In the FY2008 Section 319 work plan
negotiation process, Region 3 clarified that states no
longer need to provide an annual summary of Section 106
quarterly reports; plus, a Section 319 annual summary
was never required. (Applies to W15.)

07/07/2008 - An XML upload process was released for
CRTS. This process allows states to assemble CRTS
data without being logged on. States can then log on and
upload files to CRTS directly. This process cuts down on
wait time and slow server issues which can occur if
entering data one field at a time. In addition, CRTS
recently migrated to an Oracle-based database which
streamlines data entry and minimizes server issues.
(Applies to W18.)

07/17/2007 - 07/18/2007 -At a meeting of the
Partnership and Performance Workgroup of the Environmental Council of the States (EGOS), states
recommended that grant progress reports should be required no more frequently than semi-annually
unless there is documented need for more frequent reporting.

03/2008 - Region 1 confirmed with Massachusetts that the Section 319 implementation projects report is
only required annually; the due date is February 15th for all states in the Region. (Applies to W1_8.)

Winter 2007/2008 - Region 5 and Minnesota worked together to reduce Section 319 reporting
requirements. (Applies to W36.)

07/29/2008 - OGD distributed the draft grant reporting policy to the co-chairs of the State Grants
Workgroup, a subgroup of the EGOS Partnership and Performance Workgroup.

Fall 2008 - OGD plans to distribute and implement final grant reporting policy.

09/30/2009 - OGD expects to confirm implementation by reviewing a random sample of grant awards to
ensure the reporting terms and conditions adhere to the policy's maximum of semiannual reporting
(except in the case of poor performers or where otherwise agreed).
Page 31

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Priority Area 11 » Disadvantaged Business Enterprise (DBE) Utilization
Reporting
tate recommendations from.
States asked EPA to change Minority Business
Enterprise/Women Business Enterprise (MBE/WBE) reporting
requirements by reducing the frequency of reporting from
quarterly to annual. EPA's Office of Small Business
Programs (OSBP) responded with a new rule that reduced
quarterly reporting requirements to a semi-annual frequency.

For each grant and cooperative agreement awarded by EPA,
the recipient must describe how they are using their funds to
benefit minority- and/or women-owned enterprises. This is
known as MBE/WBE utilization. Some grants/agreements
require MBE/WBE utilization reporting every quarter; others
require annual reporting. A new Disadvantaged Business
Enterprises (DBE) Rule took effect on May 27, 2008. Among
other changes, the rule instituted a requirement for semi-
annual reporting for any grant or cooperative agreement that
previously required quarterly reporting.

Typically, grant types that had previously reported quarterly
are of a short duration. Moving to annual reporting for these
grants would eliminate OSBP's opportunity to monitor
compliance with the program. By the time OSBP received the
annual report, the grant term would be over and efforts to ensure compliance would come too late. Grants
that report annually have project periods that are longer than one year. Thus, the opportunity for program
monitoring on an annual basis is sufficient. In an effort to strike a balance, lessen the reporting burden, and
allow for effective program monitoring and compliance, the requirement for quarterly reporting was changed
to semi-annual.

The MBE/WBE Reporting Fact Sheet lists which grants/agreements have a semi-annual reporting frequency
and which have an annual frequency. Or, you may reference Section III, Part 5 of the preamble to the
regulation at 73 FR 15904.
Illinois
Indiana
Massachusetts
Nebraska
New Hampshire
South Carolina
Virginia
Timeline / Documentation
10/30/2007- 11/01/2007-Office of Small and
Disadvantaged Business Utilization (OSDBU) national
training conference was held to introduce new program
requirements to EPA grantees, small businesses, and
Agency personnel.

03/25/2008 - Email to all grantees announced the Federal
Register publication date of the new regulation.
PA Responses
Nationwide Resolution
GZ

Status
Implemented
In Part
Type of Resolution: Regulatory
03/26/2008 - The final rule was published in the Federal Register at 73 FR 15904
(http://edocket.access.qpo.qov/2008/pdf/E8-6003.pdf)

04/23/2008 - EPA's Office of Small Business Programs (OSBP, formerly OSDBU) participated in a
Region 6 state grantee teleconference to discuss program changes.

04/29/2008 - OSBP delivered a presentation at the State/EPA State Review Framework (SRF) Work
Group Meeting on how the new Disadvantaged Business Enterprises (DBE) Rule affects the SRF
Program.
Page 32

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05/2008 - The DBE page of OSBP's Web site (http://www.epa.gov/osdbu/grants.htm') was launched,
including program fact sheets and other resources. An online training module is forthcoming.
05/20/2008 - OSBP presented live training on the DBE Rule to EPA Region 5 state grantees at a joint
meeting held in St. Paul, Minnesota.

05/27/2008 - Effective date of the DBE Rule. All grants issued after this date include detailed
information on  the DBE program changes, including the change to a semi-annual reporting frequency.

06/11/2008 - OSBP presented training to the State of Wisconsin at a meeting held in Madison.

10/2008 - OSBP will provide training on the DBE Rule at the State/EPA Workgroup meeting in Kansas
City.

OSBP is in the process of identifying other established state grantee meetings where participation would
be most effective. Information about those meetings will be conveyed through the regional program
coordinators.
                                         Page 33

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Priority Area  12 » Underground Injection Control (UIC) Reports
                                                            tate recommendations from.
                                                                 Arkansas
                                                                 Connecticut
                                                                 Massachusetts
                                                                 Maine
                                                                 Rhode Island
                                                                 Texas
                                                                 Utah
The Underground Injection Control (UIC) Program is
responsible for regulating the construction, operation,
permitting, and closure of injection wells that place fluids
underground for storage or disposal. EPA is required by the
Safe Drinking Water Act (SDWA) to develop minimum federal
requirements that protect public health by preventing injection
wells from contaminating underground sources of drinking
water.

Under the parameters of SDWA and UIC federal regulations,
EPA instructs states regulators and regions, as well as
owners and operators of injection wells, on how to safely
operate injection wells to prevent contamination of
underground drinking water resources.  EPA offers extensive
guidance on the UIC program, as well as grants allocated to
state, territorial, and tribal UIC programs to help them enforce
the minimum federal UIC requirements.

States asked to eliminate duplicative UIC reporting, reduce
the frequency of reporting, and reduce the data elements
requested.  Additional concerns were that the UIC program is
chronically under-funded, and is a relatively small grant
included in the state Performance Partnership Grants (PPGs).

EPA has  responded to the states' recommendations by creating a new central UIC database, which was
launched in December 2007. Testing and implementation of the new UIC database is underway, in
collaboration with an integrated project team (IPT) composed of five states and seven Regional Direct
Implementation (Dl) programs. The IPT is collecting necessary information in order to eliminate current
versions of paper and electronic reports and streamlining data elements. Additionally, a joint State-EPA Data
Management Steering Committee is overseeing implementation to assure data quality and completeness.
While testing is underway, early participants are still required to submit official reports in the traditional
format.

EPA believes it is critical to build its capacity to access UIC well-specific information that is efficient,
accurate, and usable. Once fully populated, the database will be used to respond to information requests
from EPA management, Congress, and other governmental leaders and the public. Additionally, with the UIC
program beginning  its critical efforts to develop a national regulation for geological sequestration, EPA will
need information that can be centrally housed in the database to oversee sequestration activities.  For more
on the proposal on federal requirements for carbon dioxide (CO2) geologic sequestration wells, please see
the July 25, 2008 Federal Register notice.

At the time of this report, EPA's goal is to have all UIC primacy programs joined to the new UIC database by
2012.
                                            Page 34

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Timeline / Documentation
EPA Responses
Nationwide Resolution
W17
W26

Status
Started But Not Finished
Will Not Be Implemented
Type of Resolution: Policy
. 09/2005 - 12/2005 - EPA completed a state-by-state
assessment of the data available from the 40 State DIG
Primacy Programs. From this assessment, EPA
determined data needs based on primacy data
collection, existing regulations, and DIG owner/operator
requirements.

. FY2007 - First round testing for pilot data system and
quality of submitted data. Participants include eleven
DIG programs: four states and seven EPA Regional
Direct Implementation (Dl) programs. Focus on Quality Assurance/Quality Control (QA/QC).

04/24/2007 - 04/26/2007 - EPA presented and participated in the annual EPA Exchange Network
Forum, hosted by EGOS to exchange data transfer techniques and opportunities with all the state
environmental agencies.

11/2007 - With the Ground Water Protection Council (GWPC) representing all State DIG Primacy
Programs, a joint State/EPA Data Management Steering Committee (DMSC) was established and has
met 4 times since and will continue to meet quarterly henceforth.

. 12/2007 - Launch of DIG Database. Since that time, data has been submitted quarterly from the initial
four states and seven EPA regions based on an FY2008 data submission schedule.

12/2007- EPA's Office of Ground Water and Drinking Water (OGWDW) announced the launch of the
National Underground Injection Control (DIG) Database.

. FY2008 - Second round testing year for efficacy of new data system and quality of submitted data.
Participation expanded to include 16-22 additional DIG programs.

04/29/2008 - 05/01/2008 - EPA continues to present and participate in the annual EPA Exchange
Network Forum, hosted by EGOS, to exchange data transfer techniques and opportunities with all the
state environmental agencies.

. 05/2008 - EPA trained all the Regions at a special "Train-the-Trainers" meeting in order for Regions to
train each primacy state to use the DIG Database.

. 09/2008 - Ground Water Protection Council Annual Forum, Cincinnati, OH. EPA Headquarters and
Regions will meet for the third time in three years with all the primacy states at the national meeting of
the Ground Water Protection Council (GWPC) to outline the advantages for participating in the database.

10/2008 - 12/2008 - Based on the training provided to the Regions in May 2008, EPA Regions will meet
with every primacy state to further train the states in how to structure state databases and flow data to
the EPA UIC database.

• 2008 - 2012 - With the five primacy states and seven regions that run state programs, EPA is continuing
to work within an Integrated Project Team (IPT) to support the implementation of the new UIC database
as models for all other primacy states and EPA regions. By the end of 2008, EPA anticipates reaching
agreement with twenty-two additional UIC primacy programs on how and when to flow data into the new
UIC database. Fifteen additional states (including the Navajo nation) have received EPA Exchange
Network Grants through FY-08 to flow UIC data through the Exchange Network into the new UIC
database. Thirty-five other UIC primacy programs will be addressed after 2008.

• More information about the agency's UIC program and specific information on UIC data under the
Exchange Network framework is available online
Page 35

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Priority Area 13 » Clean Air Act (CAA) National Emissions Inventory (NEI)
Reporting
tate recommendations from.
• Connecticut
• Iowa
• Maryland
• Massachusetts
• Utah
Five states - Connecticut, Iowa, Maryland, Massachusetts,
and Utah - recommended ways to streamline National
Emissions Inventory (NEI) reporting. EPA's Office of Air
Quality Planning and Standards (OAQPS), within the Office of
Air and Radiation (OAR), is developing a new reporting
database that will meet the states' recommendations. This
database is called the Emissions Inventory System (EIS) and
will be available via the Internet so that EIS stakeholders (i.e.,
states, local government, and Tribes) can enter and access
data online. Eventually, the public will be able to view NEI
data using EIS also.

There are four components to EIS:
The EIS Gateway.
. Submission access through EPA's Central Data
Exchange (CDX). CDX is the point of entry for
environmental data exchanges to EPA. CDX enables
EPA to work with stakeholders - including state, tribal,
and local governments and regulated industries - to
enable streamlined, electronic submission of data via the Internet.
. Public access to data.
. Tools and resources.

The EIS Gateway, which is a secure Web site for EIS stakeholders, is the first component under
development. Parts of OAR, EPA Regions, and EIS stakeholders will be able to use the EIS Gateway. From
the Gateway, stakeholders will be able to:
. Add, view, and edit facility inventory data.
. Gain access to all EIS data.
. Access emissions inventory resources (e.g., reporting instructions, reporting format, reporting code
tables).

OAQPS expects to launch the EIS Gateway in October and distribute user guides at the same time. OAQPS
is planning to launch the second component of EIS - submission access through CDX - in time for the 2008
inventory cycle. In other words, OAQPS plans to launch EIS by June 2009, and states will have a year to
enter data for the 2008 report, which is due in June 2010. This second component also includes populating
EIS with historic inventory data.

States serve on ongoing work groups to define EIS requirements and enhancements. Interested individuals
may learn more at the EIS Web site. Further details about how EPA met each state's recommendations are
available under the recommendations related to this priority area. Go to A1_ for details about Maryland's
recommendation, and go to A12 for details about the other states' recommendations.
Page 36

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Timeline / Documentatii
  Summer 2007 - Region 3 clarified with Maryland that
  Region 3 grantees only need to enter their data into NEI
  once and by a specific due date (this process
  encompasses both Area Source and Mobile Source
  Inventories). The final negotiated FY2008 work plan
  commitment reflects a single due date for submission.
  (Applies to A1.)

  10/2008 - Launch the EIS Gateway and provide states
  with user guides.

  01/2009 - Populate EIS with historic emissions inventory
  data.

  07/2009 - Allow states to submit NEI data into EIS via CDX.
      Responses
Nationwide Resolution
A12


Status
Started But Not
Finished
Regional Resolution(s)
Al

Status
Implemented

Type of Resolution: Policy
                                          Page 37

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Priority Area 14 » Clean Air Act (CAA) Inspection & Maintenance Program
Reporting
State recommendations from.
• Illinois
• Maryland
• Massachusetts
• New Hampshire
• Virginia
Vehicle inspection and maintenance (I/M) programs help
improve airguality by identifying high-emitting vehicles in
need of repair (through visual inspection, emissions testing,
and/or downloading fault codes from a vehicle's onboard
computer) and requiring repair as a prerequisite to vehicle
registration within a given non-attainment area. The 1990
Amendments to the Clean Air Act made I/M mandatory for
several areas across the country, based upon various criteria,
such as air quality classification, population, and/or
geographic location. Approximately 34 states now operate
I/M programs.

Five states - Illinois, Maryland, Massachusetts, New
Hampshire, and Virginia - requested changes to EPA's I/M
reporting and/or program evaluation requirements. In
general, the states' recommendations centered on reducing
the amount and specificity of data required in the I/M
regulations at 40 CFR 51.366 as well as the frequency of the
required reports. Details about each state's
recommendations can be found under Recommendations
A10 and A21.

EPA is working with states to introduce more flexibility in I/M reporting. In 2007, for example, EPA's Office of
Air and Radiation (OAR) provided states with a checklist enumerating the data needed for I/M reports. This
checklist also provided states with an opportunity to direct EPA staff to existing sources of the data, such as
Web sites or state databases. As long as EPA staff can collect necessary data from these existing sources,
states need not submit to EPA a reformatted I/M report on the same data. Also, for the past two years, OAR
has hosted a workshop with its Regional I/M contacts to review I/M reports received from the states and
discuss program improvements based on states' submissions.

An EPA-run stakeholder group meets approximately monthly to address I/M implementation issues raised by
states. EPA also co-chairs a Federal Advisory Committee workgroup, formed in 2006, which meets regularly
to discuss opportunities for innovation presented by vehicle's onboard diagnostics (OBD). Starting with
model year 1996, vehicles are able to store emission control status information in their onboard computers,
while also alerting the driver when repairs are needed. As the percentage of the existing vehicle fleet with
OBD capabilities increases overtime, state I/M programs will become more standardized. The state-EPA
advisory workgroup is discussing how to use OBD to reduce the implementation burden and customer
inconvenience associated with I/M programs. For example, beginning in 2008 and continuing through 2009,
EPA will be developing guidance to assist states with implementing and evaluating their OBD-centered
programs. Furthermore, in recognition of OBD's potential to reduce the implementation burden associated
with I/M programs while also increasing their cost-effectiveness, EPA amended the I/M regulations in 2001 to
allow states to replace traditional tailpipe testing with OBD-based programs.

OAR welcomes further discussions with states on how to make the I/M program more effective and flexible.
All states are welcome to join the monthly EPA-run stakeholder group and raise concerns and questions they
may have with their I/M programs. At this time, however, EPA will not reduce reporting frequency or detail of
the I/M reporting requirements. There are two reasons for maintaining the I/M reporting requirements' level
of detail and frequency.

First and foremost, the program is important for controlling air pollution. Pollution from mobile sources
contributes to two of our worst urban air pollution problems - smog and carbon monoxide (CO). On-road
mobile source emissions account for approximately 51 percent of the CO, 29 percent of the hydrocarbons
(HC), and 34 percent of the nitrogen oxides (NOx) in our nation's air (based on 1999 data, see EPA's mobile
Page 38

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source emissions Web page). For on-road mobile sources like cars and light-duty trucks, the I/M program is
a principal method used to address mobile source pollution in severely polluted major urban areas.  Detailed
reports allow EPA to ensure that I/M programs are being implemented in compliance with approved State
Implementation Plans. They also help EPA (and the states) identify recurring problems with specific vehicle
makes or models, or with specific diagnostic equipment and can also help identify other implementation
challenges that may prevent states from meeting their emission reduction goals.

The second reason EPA will not reduce reporting frequency or details right now is because the Agency has
committed to a number of corrective actions for the I/M program with EPA's Office of the Inspector General
(PIG).  In October 2006, the OIG issued a report entitled EPA's Oversight of the Vehicle Inspection and
Maintenance Program Needs Improvement.  It found that EPA needs to improve its ability to determine
whether I/M programs are achieving the emission reductions claimed by making sure that states comply with
existing I/M reporting requirements. EPA's ability to reduce the reporting burden at this time is therefore
limited by both the Clean Air Act's statutory requirements (in the case of mandatory program evaluation
requirements) and the Agency's commitment to improve reporting compliance made in response to the IG's
report. Please note, however, that part of the Agency's corrective action commitments is to comply with
Office of Management and Budget recommendations for reducing state burden. The steps described above
illustrate EPA's commitment to reduce reporting burden, and OAR hopes to continue working with the states
to further improve the program.
Timeline / Documentatioi
                                                       PA Responses
Nationwide Resolution
A21

Status
Started But Not
Finished
Regional Resolution(s)
A10
/
Status
Withdrawn
                                                         Type of Resolution:
                                                            .   A10: Policy
                                                            .   A21: Regulatory & Statutory
April 2001 - EPA publishes amendments to the I/M
reporting requirements to reduce the reporting burden
for states moving to onboard computer based testing.

May 2006 - In collaboration with the National
Association of Clean Air Agencies (NACAA), EPA meets
with I/M states to discuss how EPA can better serve the
states' needs, including EPA's commitment to use I/M
test data reported by the states to identify and resolve
testing issues for various makes and models of vehicles.

September 2006 - EPA convenes an EPA-state
workgroup to address innovative ways to implement I/M
programs based upon OBD-based testing.

October 2006 - OIG issues report entitled EPA's  Oversight of the Vehicle Inspection and Maintenance
Program Needs Improvement, concluding, among other things, that EPA needs to increase enforcement
of the I/M reporting requirements.

January 2007 - EPA responds to I/M audit report with a proposed Corrective Action Plan that notes,
among other things, EPA's intention "To ensure that states are  allowed maximum possible flexibility to
provide the required information in whatever format is most convenient, in compliance with OMB
recommendations for reducing the respondent burden associated with mandatory data collections."

Winter 2007 - EPA (Region 3) clarifies with Maryland that there are no semi-annual I/M reporting
requirements. (Applies to A10.)

May 2007 - EPA develops and distributes a checklist of I/M reporting requirements to serve as a
reminder to states as well as to provide states the opportunity to reduce their reporting burden by
directing EPA to pre-existing reports or other sources of the required information, thereby eliminating the
need to reformat the information specifically for EPA.
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Priority Area 15 » Safe Drinking  Water Information System (SDWIS)
                                                           tate recommendations from.
                                                                Florida
                                                                Iowa
                                                                Maryland
                                                                Massachusetts
                                                                Montana
                                                                South Carolina
                                                                Tennessee
                                                                Texas
The Safe Drinking Water Information System (SDWIS) federal
and state databases contain information submitted by states,
EPA regions, and public water systems in conformance with
reporting requirements established by the Safe Drinking
Water Act (SDWA) and related  regulations and guidance.
These statutes and  accompanying regulations establish
maximum contaminant levels, treatment techniques, and
monitoring and reporting requirements to ensure that water
provided to customers is safe for human consumption. The
Safe Drinking Water Query within SDWIS allows users to
locate their drinking water supplier and view its violations and
enforcement history for the last ten years.  In this manner,
data management plays a  critical role in  helping states and
EPA protect public health.

EPA's Office of Water (OW) collaborates with states on a
number of groups (SDWIS Data Sharing Committee,  SDWIS
Data Management Steering Committee,  Association of State
Drinking Water Administrators,  etc.) to recommend and make
improvements to SDWIS and the collection of drinking water
information. In addition to  participation on two different data
committees, there is an annual  conference and monthly calls
where states may raise their concerns to EPA.  States had a
number of recommendations related to streamlining reporting
elements and eliminating duplicate reporting.

While many of the recommendations in this priority area directly relate to changes that have been or could
potentially be made to the  SDWIS databases, others  relate to enforcement or region-specific reports. A brief
description of each  is outlined as follows:

•  W1 - Streamlining SDWIS  - Massachusetts, Montana, and Texas all reported a variety of reporting that:
   duplicated data submitted elsewhere, required state staff to verify data, or required states to perform time-
   consuming queries to build a report.  EPA made significant modifications to SDWIS-Fed in 2006, which
   has streamlined  data calculation, data queries, and other data extraction. The Office of Ground Water
   Drinking Water (OGWDW) confirmed that data verification is necessary to ensure data quality, and is
   typically done biennially via  national surveys.

•  W3 - Significant noncompliance reporting - Iowa, Massachusetts, and Texas requested revisions to
   EPA's significant noncompliance (SNC) determinations, reporting, or verification. The modifications made
   to SDWIS-Fed in 2006  have corrected errors to the Public Water System (PWS) quarterly noncompliance
   reports and  streamlined SDWIS further to generate lists of new systems in SNC.  However, the new SNC
   calculation tool is still under  development.

•  W27- Data sharing -  Massachusetts, Maryland, Montana, and South Carolina all requested
   streamlining of SDWIS  to contain related information and to extract the data in a more efficient manner.
   With the exception of Underground Injection Control (DIG) data, which is outlined in Priority Area 12,
   many ground water systems have already been added or will  be added to SDWIS.  Additionally, SDWIS
   has been updated for queries on public water system information.

•  W31 - Ground Water reporting - Florida requested that the SNC report used for capacity development
   be eliminated. While the calculation formula for SNC that forms the basis of the capacity development
   report is under development (see Recommendation  W3), EPA's Office of Ground Water and Drinking
   Water will still require that states provide reasons  for systems in historical SNC or new systems in SNC.
   Meanwhile,  Tennessee requested that SDWIS accept only changed  or modified data elements. EPA
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believes that the modernized SDWIS-Fed has made the electronic data exchange more efficient for
updating entire data files.

• W33 - Sanitary surveys - Both Florida and Massachusetts made recommendations for changes to
EPA's sanitary survey collection requirements. In response to Florida, EPA Region 4 has agreed that the
state does not have to submit an annual list of completed sanitary surveys. Region 4 will extract this
information from SDWIS-Fed, if that is what the state prefers. Massachusetts' request was to not
duplicate sanitary survey data collection in both SDWIS and the Integrated Compliance Information
System (ICIS). EPA confirmed that state sanitary survey information is only collected in SDWIS, and not
in ICIS.

• W34- Operator certification - Massachusetts asked to eliminate the annual narrative report of the
operator certification program and to instead be allowed to enter the information into SDWIS. EPA plans
to discuss this with its Data Sharing Committee.
Timeline / Documentation
PA Responses
Nationwide Resolution
W1
W3
W27

W31

W33

W34

Status
Started But Not Finished
Started But Not Finished
Started But Not Finished
Will Not Be Implemented
Implemented
Started But Not Finished
Type of Resolution: Policy
Ongoing

States are integrally involved in making data and policy
changes related to drinking water information systems.
Among the ongoing activities occurring are the following:

. The SDWIS Data Sharing Committee, comprised of states
and EPA, reviews and recommends changes and
additions related to SDWIS. This Committee is comprised
of at least 7 states and 3 EPA employees and meets
monthly by conference calls. In addition, several states
participate informally in this Committee.

. The SDWIS Data Management Steering Committee,
comprised of states and EPA, evaluates all information
system-related policy issues. This group consists of at
least 7 states and 3 EPA employees and also meets
monthly.

. EPA conducts monthly SDWIS primacy agency calls, which are open to all drinking water data users
including states, territories, EPA Regions, and contractors to discuss anything related to drinking water
data management- reporting issues, training, implementation questions, etc. Typically between 20 and
30 states participate in monthly teleconferences.

. The Association of State Drinking Water Administrators (ASDWA) and EPA jointly conduct an annual
Data Management Users Conference (DMUC).

. EPA also relies on input from states in numerous ASDWA/EPA workgroups, most recently the SDWIS
Requirements Session at the annual DMUC in May 2008. Visit the SDWIS Meeting and Announcements
Web page to learn more about these ongoing activities.

Additional Timeline of SDWIS deliverables:

01/2006 - Update made to modernize SDWIS-Fed. SDWIS-Fed extracts data from SDWIS-State on a
quarterly basis. This change shifted the data of record from production data, which could change at any
time, to quarterly frozen data.

. 11/2007 - A Long-Term 2 (LT2) module was built into SDWIS-State.

. 2008 - SDWIS-Fed updated for entry of sanitary survey data.

05/06/2008 - 05/08/2008 - Nashville, TN. Annual ASDWA/EPA Data Management Users Conference.
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10/20/2008 - 10/22/2008 - Colorado Springs, CO. Annual ASDWA conference.

2008 - Data  Sharing Committee will discuss whether to add data element for outstanding performers on
a 5-year sanitary survey cycle.

2008 - Source Water Protection (SWP) element will be added to SDWIS State and Fed. See EPA's
Drinking Water Data and Databases for more information.

2008 - Data  Sharing Committee will discuss whether to evaluate options that would allow states to report
reasons systems are on Significant Noncompliance (SNC) lists (as required through the capacity
development reports) through SDWIS.

2008 - Data  Sharing Committee will discuss whether to include operator certification reporting in SDWIS.

2008-2009 - Joint pilot testing of system-based electronic data verification tool, or SNC desktop
calculator, with the Association of State Drinking Water Administrators and EPA.
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Priority Area 16 » Quarterly Grant Reports
tate recommendations from.
Three states - Maryland, Michigan, and Wisconsin -
recommended that grant reports be required no more than
annually. EPA's Office of Grants and Debarment (OGD) is
developing a standardized grant reporting policy that
addresses these recommendations in three ways:
1. Progress reports - The policy will reduce quarterly
grant progress reports to a frequency of no greater
than semi-annually, except in instances of poor
performers or where Regions and states have
otherwise agreed. In many cases, reporting
frequency will be reduced to a frequency of no
greater than annually. If a state uses a Performance
Partnership Grant (PPG) and the PPG encompasses
only those grants/agreements with annual reporting
requirements, then a progress report will be due
annually. If the PPG encompasses some
grants/agreements with a semi-annual frequency and some with an annual frequency, then the state
will have the option to either a) report semi-annually on the entire PPG or b) report semi-annually on
only those portions of the PPG that require twice yearly reporting.
2. Financial Status Reports (FSRs) - The policy will reduce reporting frequency for FSRs to no more
than annually.
3. Federal Cash Transaction Reports (FCTRs) - OGD anticipates that the policy will limit FCTRs to a
frequency of no more than semi-annually; however, the Office of Management and Budget and the
Department of Treasury have to approve this reduced frequency before EPA can insert it in the
policy.

The draft policy has been circulated for review by members of the Environmental Council of the States' State
Grants Workgroup. A final version is expected in fall 2008.
Maryland
Michigan
Wisconsin
Timeline / Documentation
07/17/2007 - 07/18/2007 -At a meeting of the
Partnership and Performance Workgroup of the
Environmental Council of the States (EGOS), states
recommended that grant progress reports should be
required no more frequently than semi-annually unless
there is documented need for more frequent reporting.
PA Responses
Nationwide Resolution
G8

Status
Started But
Not Finished
Type of Resolution: Policy
07/29/2008 - OGD distributed the draft grant reporting policy to the co-chairs of the State Grants
Workgroup, a subgroup of the EGOS Partnership and Performance Workgroup.

Fall 2008 - OGD plans to distribute and implement final grant reporting policy.

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    Appendix:
Recommendations
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Recommendations Related to the Office of Air &

Radiation (OAR)

A1: Eliminate Duplicative National Emissions Inventory (NEI) Reporting

Priority Area: This recommendation falls under Priority Area 13. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends:
. Eliminate redundant reporting
. Streamline databases
States' Original Input
Reduce duplicative reporting/ multiple submissions in National Emissions Inventory. (MD)
EPA Response
Region 3 grantees only need to enter their data into NEI once and by a specific due date (this
process encompasses both Area Source and Mobile Source Inventories). Region 3 clarified this
issue with the state through the grant work plan negotiation process. The final negotiated FY2008
work plan commitment reflects a single due date for submission.
A2: Reduce Reporting Frequency for Clean Air Act (CAA) Section 105 Grant
Reporting

Priority Area: This recommendation falls under Priority Area 1. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends:
. Reduce reporting frequency
. Eliminate low-value data requirements
States' Original Inpu
Change Section 105 grant work plan quarterly reports to an annual report. (AL)

End requirement for Section 105 quarterly reports to be submitted to EPA grant personnel. Require
grants personnel at the Regional level to work with program personnel in order to pull information
already submitted to EPA. (KY)

Eliminate requirement for annual narrative summary report comparing actual accomplishments to
work plan's anticipated outputs/outcomes. Require only if grant requirements and commitments are
not met. (KY)
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Eliminate required narrative summary of mobile source outreach and voluntary program activities in
progress. (KY)
Eliminate required narrative summary of mobile source outreach and voluntary program activities.
Most, if not all, of this information may be found in the Early Action Compact progress reports. (SC)
At a national level, EPA is developing a standardized grant reporting policy that will pertain to Section
105 grants, as well as a number of other grants and assistance agreements. See Priority Area 1 for
more information.

EPA Region 4 also addressed the states' recommendations:

o Section 105 quarterly grant reports -
• Alabama recommended changing from a quarterly to an annual reporting frequency. The
determination of whether any one quarterly progress report currently required can be
deleted from Alabama's Section 105 grant agreement needs to be made on a case-by-
case basis with EPA. Alabama should discuss specific quarterly reporting items with
Region 4. Alternatively, Alabama may wish to wait until the EPA-wide grant reporting
policy (described in Priority Area 1) is instituted later this year. It covers Section 105
grant reporting as well as all other grant reporting.
• Kentucky recommended that grant reports should be submitted only once - to EPA
program personnel - and not a second time to EPA grant personnel. Region 4 agrees.
Section 105 grant reports need to be submitted only once; all reports should be submitted
to the administrative project officer.

o Section 105 annual narrative summary - Kentucky recommended that the annual narrative
summary be required only if grant requirements and commitments are not met. Region 4 expects
grantees to provide an explanation for why commitments in their Section 105 grant work plan
were not met or significantly delayed. Thus, Kentucky's position and EPA's position on this
matter are essentially the same: states needs to report annually on only those grant commitments
which were not met or were significantly delayed and the reasons why.
o Narrative summary of mobile source outreach and voluntary program activities - Kentucky
and South Carolina recommended that Region 4 eliminate the mobile sources report under
Section 105 grant reporting. Region 4 agreed.
A3: Eliminate Evaluation Report on Ambient Air Monitors and Auxiliary
Equipment
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Original In
Eliminate report on evaluation of ambient air monitors and auxiliary support equipment; eliminate
certification that state completed evaluation. (SC)
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A4: Eliminate Report on Technical Training

Eliminate annual report on the technical training supported with Sec. 105 funds. (SC)
A5: Eliminate List of Metropolitan Statistical Areas for Which Air Quality Index Is
Reported
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Eliminate list of metropolitan statistical areas for which air quality index is reported to the general
public. Already reported to EPA's AIRNOW Web site. (SC)
A6: Eliminate Report on "No Determinations" Under Clean Air Act (CAA) Section
112(9)
Priority: This recommendation falls under Priority Area 2. Click on the hyperlink to learn more about this
priority area.

Status: Implemented

Trends: Eliminate redundant reporting
States' Original Input
Eliminate requirement to submit a notice if no Sec. 112(g) determinations are made in a given year. It
is redundant since states are required to enter determinations into the 112(g) clearinghouse. (KY)
Eliminate requirement to submit a notice if no Sec. 112(g) determinations are made. All
determinations are submitted via 112(g) Clearinghouse. (SC)
EPA Response
Region 4 removed this requirement for FY2008 for all state and local air agencies in the Region,
including Kentucky and South Carolina. The twenty-four state and local agencies were notified on
August 24, 2007.
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A7: Eliminate Report on Prevention of Significant Deterioration/ New Source
Review (PSD/NSR) Non-Applicability Determinations

Priority Area: This recommendation falls under Priority Area 2. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate low-value data requirements
States' Original Input
Eliminate requirement to report Prevention of Significant Deterioration/ New Source Review
(PSD/NSR) applicability determinations resulting in non-applicability. The value of the report is
unclear. The list must be prepared manually because no state or federal database requires the
information but instead only requires applicability data. (KY)

Eliminate list of PSD/NSR applicability determinations resulting in non-applicability. (SC)
EPA Response
Region 4 has met South Carolina's request. Region 4 has not required reporting on non-applicability
for a number of years because South Carolina now explains why PSD/NSR does not apply in public
notices for their permits.

On April 2, 2008, Region 4 and Kentucky made the same arrangement: Kentucky will note non-
applicability in their public notices and thus will not be required to submit a PSD/NSR non-applicability
report.
A8: Eliminate List of Maximum Achievable Control Technology (MACT)
Categories for Which State Has Received Delegation

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007. But, we wanted to list it here to ensure that a full list of all states'
submission is provided.
States' Original Input
Eliminate required list of Maximum Achievable Control Technology (MACT) categories for which state
has received delegation. All MACT standards already incorporated by reference and compliance
status already available from EPA AIRS Facility Subsystem (AFS) database. (MT)
A9: [Recommendation deleted - same as E14]

In March 2008, EPA released a draft progress report on the Burden Reduction Initiative. The March report is
the first time codes such as "A9" and "E14" were introduced. The same codes are used herein. Because
this report's primary audiences - state and EPA personnel working on the Initiative - are familiar with the
March report, it is important to offer an explanation when a recommendation that was in the previous report
does not appear here. In the case of A9, it was deleted because it was identical to the recommendation in
E14.
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A10: Reduce Reporting Frequency of the Inspection and Maintenance (I/M)
Semi-Annual Report

Priority Area: This recommendation falls under Priority Area 14. Click on the hyperlink to learn more about
this priority area.

Status: Withdrawn

Trends: Reduce reporting frequency
States' Original Input
Eliminate the Inspection and Maintenance semi-annual report. Change to annual reports. (MD)
EPA Response
A staff person in Maryland was under the impression that there are semi-annual I/M reporting
requirements, but this is not the case. There are no twice yearly I/M reporting requirements. Region
3 has clarified this with Maryland.
A11: Eliminate Quarterly Report on Conformity Consultations

Priority Area: This recommendation falls under Priority Area 13. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Streamline databases
States' Oriainal Incut
Eliminate multiple submissions required under the National Emissions Inventory (NEI), Area Source
Inventory, and Mobile Source Inventory. (CT)
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State is required to report two types of emissions data for NEI: 1) data from large point sources (on
an annual cycle) and 2) data from all point, nonpoint, and mobile sources (on a three-year cycle).
State must transfer data from State's Oracle database to EPA's Access database. Specific coding
requirements called NEI Input Format (NIF) make entry into Access database highly burdensome.
Loosen NIF coding requirements. (IA)

Facility and emission point location information is required in both latitude/longitude (lat/long) and
universal transverse mercator (UTM). Eliminate use of UTM systems and rely solely on lat/long.
Modify requirements for non-major sources so they need only report the lat/long for the facility as the
location of the emission release point. (MA)

Modify data required for emission release points for non-major sources. Require detailed emission
release point information for major sources only. Specifically, non-major sources should not be
required to complete, or the state submit, the following data elements: emission release point height
measure, emission release fugitive width, emission release point fugitive release angle, emissions
release point stack fence line distance measure, emissions release point stack diameter, emission
release point exit gas velocity measure, emissions release point exit gas flow rate measure, and
emissions release point exit gas temperature. (MA)

EPA has replaced, added, or augmented Utah's NEI data with other data, such as TRI, acid rain, etc.
Once EPA has made modifications to data, responsibility for the data should fall to EPA. Manipulated
data should be identified for the public. (UT)
EPA Response
EPA's Office of Air Quality Planning and Standards (OAQPS), within the Office of Air and Radiation
(OAR), is developing a new reporting database that will meet the states' recommendations. It is
called the Emissions Inventory System (EIS). Go to Priority Area 13 for a general overview of
OAQPS' activities.

Specifically, here's how EIS will address each state's concerns:

o Connecticut - EIS will create one submission process. States will have an opportunity to review
data before it is finalized, but the review is voluntary.

o Iowa - EIS will make data submission more efficient. It will allow batch XML export from a state
database into EIS via EPA's Central Data Exchange (CDX). In other words, states will be able to
transfer data en masse, and XML will help translate data from one type of database to another.
"XML" stands for Extensible Markup Language. Its primary purpose is to help information
systems share structured data, particularly via the Internet.

o Massachusetts - EIS will use only lat/long facility and emission point location information. In EIS
a single facility lat/long will be required. States will also have the option of submitting a lat/long
for each of their emission release points. If states do not submit lat/long for an emission release
point, the facility location will be used. EIS will give states an informational warning message
alerting them to this fact.

As for Massachusetts' second request - to modify data required for non-major sources - the EIS
state-EPA work groups are addressing the required data elements. The September 2006 Draft
Report: Development of a New Business Process for EPA's Emissions Inventory System (found
on the EIS Web site) explains anticipated data requirements as follows:

"The content of the EPA emissions inventory developed through this reengineered
business process does not differ significantly from the historical emissions inventories for
the 2002 and earlier cycles. However, the categories of emissions inventory data and
how these data are processed have undergone streamlining and automation. Many
procedures are reduced in complexity and no longer require intensive augmentation of
data from other sources. Instead, they rely more on reported data from submitters and
better quality assurance processes to screen out incorrect or erroneous data from being
incorporated into the inventory.
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"Additional new tools, quality checks, and new processes assist submitters, reviewers,
and data consumers with extensive data analysis and information dissemination
presentation materials. Most of this information is made available to the State, Local,
Tribal and EPA agency users through the incorporation of the EIS web portal and through
a public data website." (See pg. 23.)

Interested individuals may learn how to join the state-EPA work groups at the EIS Web site.

Utah - OAQPS does indeed incorporate additional data into the NEI beyond what the states have
submitted. EIS will be able to capture multiple emission numbers and will clearly indicate the source of
each number.
A13: Eliminate Requirement to Report on Every Air Program Variance Request

Provide resources to meet expanding AIRNOW requirements, such as met, SO2, and NOx data.
Provide resources for forecasting ozone and PM levels. EPA should make it a priority to move the
AIRNOW system to the Exchange Network (which is now being piloted in NJ) and make AIRNOW
reporting more consistent with the AQS data system. (OR)
A15: [Recommendation deleted - incorporated into Recommendation A2]

In March 2008, EPA released a draft progress report on the Burden Reduction Initiative. The March report is
the first time codes such as "A15" and "A2" were introduced. The same codes are used herein. Because
this report's primary audiences - state and EPA personnel working on the Initiative - are familiar with the
March report, it is important to offer an explanation when a recommendation that was in the previous report
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does not appear here. In the case of A15, it was deleted because the recommendations in A15 were
identical to two of the recommendations under A2.
A16: Modify PM10 Reporting in Aerometric Information Retrieval System (AIRS)

-------
beginning the rulemaking process. After those comments were addressed and the process initiated,
different EPA staff reviewed the submittal and provided more comments. EPA should provide all its
comments during the draft phase. EPA has reviewed information and agreed to support the submittal
and then withdrew their support during the process. EPA should not put the state in the awkward
position of having to withdraw a proposal that it said it would support. (AL)

SIP development begins with a very burdensome EPA rulemaking process. States cannot participate
in the rule development and then are given only a short time to evaluate the proposed rule and
comment. Final rules typically come out with no implementation guidance. Guidance that is
promised is late, making it difficult to meet SIP deadlines. The process is so slow that it is almost
impossible to prepare and submit a SIP before there are significant program, guidance, or personnel
changes that negate the process. (NV)
A20: Improve the Federal Air Program Rulemaking Process

Priority Area: This recommendation falls under Priority Area 14. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Reduce reporting frequency
. Eliminate low-value data requirements
. Streamline databases
States' Original Input
Review and update Inspection/ Maintenance (I/M) reporting and program evaluation requirements to
reduce burden and require only data that is of value. State does not receive feedback from EPA as
result of submitting the required reports and therefore cannot determine value of such high-burden
reporting. The efficacy of detailed I/M data reports is questionable; in cases where EPA provides
technical evaluation and assistance, states submit the required test data apart from the detailed I/M
reports. (IL)

Eliminate biennial report. Add data elements in the biennial report that are not presently in the annual

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report to the annual report. Then, require only the annual report. (MA)

Streamline annual inspection/ maintenance data reports. Eliminate specific data elements required
under 40 CFR 51.366 and replace with more general requirements for overall program statistics.
Manipulating data into the format specified by the regulation requires considerable effort. (NH)

40 CFR 51.366 Annual I/M data reporting - Summary statistics of I/M program - This reporting
requirements is a significant expense in terms of staff time. Additionally, the program is a biennial
program. If reports are needed, then the reporting frequency should be every 2 years, at a minimum,
to capture a picture of the entire program. There is no evidence that the Regional Office looks at
these reports. EPA should compile and make the reports available. Only data useful in evaluating
programs should be maintained. Since it is a biennial program, the reporting frequency should be
changed to biennially, at a minimum. (VA)

40 CFR Section 51.353(c) Biennial Program Evaluations - Summary statistics of I/M program - Since
OBD test results do not provide quantitative emissions reductions, it is extremely expensive to gather
the data necessary to prepare this report. This requirement should be dropped or redefined with
specific, cost-effective procedures. (VA)
EPA Respons
EPA senior leadership will meet in fall 2008 to discuss if and how these recommendations will be
implemented. Further discussion is needed for two reasons:

o The I/M program provides important environmental protection from excessive pollution from on-
road mobile sources. Further, some of the recommendations may require statutory change. The
biennial I/M program effectiveness evaluation requirement is a Clean Air Act requirement under
Section 182(c)(3)(C) and the annual reporting requirements are regulatory (40 CFR 51.366).
These requirements are necessary tools to address mobile source pollution in the more severely
polluted major urban areas

o Meeting the states' requests may contradict earlier commitments for corrective actions negotiated
with EPA's Office of the Inspector General. An audit report by EPA's Inspector General (IG),
conducted in October 2006, found that many states were not complying with existing I/M reporting
requirements. (See EPA's Oversight of the Vehicle Inspection and Maintenance Program Needs
Improvement).
A22: Streamline Public Notice Requirements for State Implementation Plan
(SIP) Permits
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
.tates' Original Input
Eliminate requirement to submit all public notices for all permits, which would allow state to revise its
regulation to issue public notices on all permits. (NE)
A23: Streamline Reporting on Ethanol Permit Applications and Prevention of
Significant Deterioration (PSD) Applications
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.

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States' Original Inpiu
Eliminate requirement to submit all information regarding ethanol permit applications and Prevention
of Significant Deterioration (PSD) applications. Provide only PSD public notice. If EPA comments,
follow up with responsiveness summary. (NE)
A24: Eliminate Annual Monitoring Equipment Purchase Form under Clean Air
Act (CAA) Section 105
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Eliminate annual form documenting monitoring equipment purchased. Equipment purchase plans are
documented in grant application. (SC)
A25: Eliminate Duplicative Inventory Reporting [newly added]
In August 2007, EPA released its first progress report on this Burden Reduction Initiative. In March 2008,
EPA released a second progress report in draft form only. EPA has tried to maintain consistency between
this progress report and the earlier ones because the primary audiences for this report - state and EPA
personnel working on the Initiative - are familiar with the previous reports. In some instances, however, it
was necessary to deviate from the previous reports. A25 is one of those instances.

A25 was added to this report after not appearing in a previous progress report because the original state
submission did not fit under any of the existing recommendations. But, A25 is not addressed in this progress
report because of the focus on the 16 priority areas. Still, it is listed here to ensure that a full list of all states'
submission is provided.
States' Original In
The Iowa Department of Natural Resources (DNR) is required by the Consolidated Emissions
Reporting Rule (CERR-40 CFR Part 51) and Air Emissions Reporting Rule (AERR) to report
emissions data annually to EPA. The AERR is currently just a proposed rule. There are also annual
emissions inventory requirements in the Clean Air Interstate Rule (CAIR), starting with the 2008
emission year. EPA should eliminate duplicative inventory reporting requirements by modifying these
rules as appropriate. (IA)
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Recommendations Related to the Office of Enforcement
& Compliance Assurance (OECA)
E1: Reduce Data Requirements for Integrated Compliance Information System
(ICIS)

Priority Area: This recommendation falls under Priority Area 6. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Streamline databases
. Eliminate low-value data requirements
States' Original In
Reexamine current proposed reporting requirements for the Integrated Compliance Information
System (ICIS) and negotiate with states a more reasonable data set. New proposed reporting
requirements for ICIS will require additional information for the National Pollutant Discharge
Elimination System (NPDES) minor facilities (more than Permit Compliance System (PCS)), as well
as substantial information on concentrated animal feeding operations (CAFOs), Sanitary Sewer
Overflow (SSO), biosolids, pretreatment, and stormwater programs. Collecting the required data will
impose an enormous burden. (AZ)

EPA is pursuing adopting new Water Enforcement National Database (WENDB) data elements that
include fields that cover compliance monitoring and evaluation data at CAFOs. EPA wants this data
added into ICIS. (IA)

New requirements being implemented by ICIS are extremely burdensome. Current state databases
do not capture all of the new elements proposed for ICIS. ICIS requirements should be more in line
with current PCS requirements. (Ml)
NPDES permitted facilities and compliance issues are maintained on a state database that meets
tracking and reporting needs. ICIS provides no value to state and requires over 100 additional data
elements not used by state. State will no longer input data to ICIS and will provide NPDES data
through Exchange Network instead. (NV)

Consider alternative suggested by the Association of State and Interstate Water Pollution Control
Administrators/Environmental Council of the States (ASIWPCA/ECOS) position paper. Consider
ways to minimize the expansion of state reporting burden via ICIS. (NY)
EPA Response
EPA is pursuing a consolidated response for Recommendation E1, E2, and E3. Please read the
summary of this response in the Priority Area 6 overview.
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E2: Reduce Data Elements in ICIS' Required Integrated Compliance Information
System Data Elements (RIDE)

Priority Area: This recommendation falls under Priority Area 6. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Streamline databases
. Eliminate low-value data requirements
States' Original Input
Due to the complexity of the transactional reporting approach for Integrated Compliance Information
System (ICIS) and compounded by the number of data elements in the Required Integrated
Compliance Information System Data Elements (RIDE), providing data into ICIS requires inordinate
resources from the state. RIDE does not take into account such processes as general permits and
does not differentiate between oversight by EPA and the day-to-day management by the state. As
the states noted in the "States' White Paper: Alternative Approaches for States to Provide EPA with
National Pollutant Discharge Elimination System (NPDES) Information," we propose that summary
data would address EPA's needs at a reduced burden to the state. (NJ)

Expanding what is required in Permit Compliance System (PCS) under ICIS-RIDE is burdensome.
Require only that which is already required by PCS. (VA)
EPA is pursuing a consolidated response for Recommendation E1, E2, and E3. Please read the
summary of this response in the Priority Area 6 overview.
E3: Streamline Data Requirements in NetDMR for NPDES Discharge Monitoring
Reports (DMR)

Priority Area: This recommendation falls under Priority Area 6. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate low-value data requirements
. Additional resources needed for additional requirements
States' Original Input
The Integrated Compliance Information System's (ICIS) required data changes amount to an
unfunded mandate. If EPA changes the data system codes or fields, it should also fund the states'
efforts to implement the changes. (MD)

The National Pollutant Discharge Elimination System (NPDES) data required of state will expand
substantially. The increase includes both the kinds of data and the number of facilities that will need
to submit data. Allow the requirements to be phased in overtime and allocate resources to states for

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this work. (OR)
EPA Response
EPA is pursuing a consolidated response for Recommendation E1, E2, and E3. Please read the
summary of this response in the Priority Area 6 overview.
E4: Eliminate NPDES Annual Noncompliance Report (ANCR)
Priority Area: This recommendation falls under Priority Area 5. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Eliminate redundant reporting
States' Original Input
Eliminate the National Pollutant Discharge Elimination System (NPDES) Annual Noncompliance
Report (ANCR) under 40 CFR Part 123.45. Data retrieval from EPA is incorrect so report is not valid.
Unable to determine what it is used for. (NE)

Eliminate ANCR. Non-major discharger data is now entered in the Permit Compliance System
(PCS). More meaningful reports can provide the same information from PCS. (SC)

1) At a minimum, change the reporting cycle for the ANCR to the federal fiscal year so that
enforcement data that is required can also be used for the State Review Framework (SRF).
2) Consider suspending the ANCR until all states are required to enter enforcement data in federal
database.
3) Alternatively, eliminate ANCR and used SRF process for EPA to oversee state enforcement
activity for NPDES minors. (TX)
EPA Response
EPA's Office of Enforcement and Compliance Assurance (OECA) is in the process of developing a
new regulation - called the NPDES Program Management Information Rule - that will address a
number of NPDES data reporting issues. As part of this new rule, OECA plans to propose eliminating
or modifying the requirement that states submit the ANCR. OECA's plans are contingent on the final
rule requiring that reporting entities input discharge monitoring report data for "minor dischargers" into
the Integrated Compliance Information System (ICIS). (ICIS is replacing the Permit Compliance
System (PCS).) As long as the ICIS data requirements defined by the rule include data on "minor
dischargers," then the information that comprised the ANCR can be retrieved from ICIS rather than
being manually submitted by states.

Currently, OECA projects the final rule will be published by October 2009. Until the rule becomes
effective, the ANCR remains as a regulatory requirement.
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E5: Eliminate Reporting Enforcement and Compliance Assurance Priorities
(RECAP) Report

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate redundant reporting
States' Original Input
The Reporting Enforcement and Compliance Assurance Priorities (RECAP) report consists of a set of
retrievals from the Permit Compliance System (PCS) database. The Region should run this report
from PCS rather than requiring the state to do it. (TX)
EPA Response
The RECAP report has not been required nationally for several years. Region 6 had been requiring
this report but now agrees that the report can be generated internally. In order to aid discussions
about compliance activities, however, Region 6 recommends that states retrieve data from PCS or
the Integrated Compliance Information System (ICIS) on the same date as Region 6 to ensure that
the state and EPA are reviewing the same data. This will help EPA and the states identify and
resolve discrepancies. Region 6 sent a letter to all Region 6 states on 08/29/2008 notifying them that
the RECAP report is not required.
E6: Eliminate or Reduce Frequency of Clean Air Act (CAA), Clean Water Act
(CWA), and Resource Conservation and Recovery Act (RCRA) Quarterly Watch
Lists

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends:
. Reduce reporting frequency
. Eliminate redundant reporting
States' Original Input
Eliminate the Watch Lists. EPA creates Watch Lists from 6-month-old data. Most facilities on the lists
are due to poor Permit Compliance System (PCS) data. (NE)

Preparing Watch Lists for the Clean Air Act, Clean Water Act, and Resource Conservation and
Recovery Act has been an unfunded mandate from EPA. It is tremendously time-consuming to
compile the information for the Watch Lists. Individual enforcement resources have to be researched
in the state and Federal databases and summary information sent in a specific format to EPA.
Eliminate the Watch Lists. Several mechanisms already allow for oversight, such as Performance
Partnership Grant (PPG) reporting. If the Watch Lists are retained, have the Region prepare the lists
instead of the state. Another option would be to focus the Watch Lists on specific cases. Finally, if
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the lists are not eliminated, reduce the frequency from quarterly to semi-annually or annually. (TX)
EPA Response
EPA will not implement the states' recommendations. The Watch List is a tool for EPA and the states
to identify and improve management of those facilities that appear to have long standing and
unaddressed significant non-compliance problems. The Watch List is created by EPA from existing
data that the states enter into three national EPA systems that track compliance under the National
Pollutant Discharge Elimination System (NPDES), Resource Conservation and Recovery Act
(RCRA), and Clean Air Act (CAA) stationary source program. EPA provides states with an easy-to-
use tool in the Online Tracking Information System (OTIS). It allows each state to generate their
Watch List for NPDES, RCRA, and CAA with the click of a button. The respective quality of the
state's data will be reflected by the list.

The method Texas has chosen to provide information on the CAA Watch List makes it more
burdensome for them, as well as for the Region. For example:

o The April 2008 CAA Watch List pulled from OTIS contained 70 facilities plus five EPA lead
facilities; the list Texas generated for the CAA had 314 facilities plus 23 EPA lead facilities.

o For the CWA Watch List, Region 6 currently sends the Watch Lists to Texas because the state
does not put enough information into the Permit Compliance System (PCS) to enable Region 6 to
respond to the Watch List for their facilities. This is particularly true for pending and planned
enforcement actions.

The two examples above demonstrate the need to continue using the Watch Lists. They help to
ensure that states and Regions are talking about the same universe of significant non-compliers, and
they help ensure that the appropriate quality of data is maintained.
E7: Improve Data Management in Enforcement and Compliance History Online
(ECHO) and Resource Conservation and Recovery Act Information Database
(RCRAInfo)

Priority Area: This recommendation falls under Priority Area 8. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Streamline databases
States' Original Input
Improve EPA handling of data submitted by states and then used in databases such as the
Enforcement and Compliance History Online (ECHO) system. The Watch List for air, water, and
waste is an EPA enforcement tool. Since data originated in the states, state agencies receive
criticism over incorrect information in ECHO. States should not be expected to check these EPA
databases and find the things that need correcting. (MD)
EPA's Office of Enforcement and Compliance Assurance (OECA) manages the ECHO Web site and
the underlying Integrated Data for Enforcement Analysis system (IDEA) (which is a database that
compiles facility information from a number of disparate EPA databases and feeds it into ECHO).
OECA has already taken many steps to reduce the formerly lengthy process for corrections to data
from states:
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The top of each ECHO facility Web report has a "Report Error" link so the facilities, states, and
public have easy access to the error correction process. Error notifications are routed to EPA
and state data contacts so they are aware of possible errors and can make corrections in
program databases.

Data in ECHO is updated on a monthly basis. Data is normally updated around the third week of
each month. Each facility report generated is date stamped. EPA National databases (containing
state and federal data) used in ECHO include the:

• Air Facility System (AFS) - collects Clean Air Act data

• Permit Compliance System (PCS) - collects National Pollutant Discharge Elimination System
(NPDES) data

• Integrated Compliance Information System - National Pollutant Discharge Elimination System
(ICIS-NPDES) - Is replacing PCS at the NPDES data system

• Resource Conservation and Recovery Act Information System (RCRAInfo) - collects
Resource Conservation and Recovery Act data

Federal-only databases used in ECHO include the:

• Integrated Compliance Information System (ICIS) - collects multi-statute enforcement data
from Regions

• National Compliance Database (NCDB) - contains records about the Emergency Planning
and Community Right-to-Know Act; the Federal Insecticide, Fungicide, and Rodenticide Act;
and the Toxic Substances Control Act

OECA has conducted random audits of ECHO to ensure a high level of data quality. You may
review these audits online.

EPA continues to accept comments on improving ECHO at echo@epa.gov.

EPA provides extensive metadata and background on ECHO to help the public understand the
data and know its limitations.
E8: [Recommendation deleted - same as W39]

In March 2008, EPA released a draft progress report on the Burden Reduction Initiative. The March report is
the first time codes such as "E8" and "W39" were introduced. The same codes are used herein. Because
this report's primary audiences - state and EPA personnel working on the Initiative - are familiar with the
March report, it is important to offer an explanation when a recommendation that was in the previous report
does not appear here. In the case of E8, it was deleted because the recommendations in E8 were identical
to the recommendations under W39.
E9: Eliminate Water Program Chronic Non-Compliers Report
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Original Input
Eliminate the chronic non-compliers report for water program, which has no prescribed format or
required level of detail. State is unclear of the purpose or necessity of report. Instead, discuss chronic
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non-compliers in annual or quarterly program reviews. (KS)
E10: Eliminate Reports That Can Be Retrieved From the Permit Compliance
System (PCS) or Enforcement and Compliance History Online (ECHO)

Priority Area: This recommendation falls under Priority Area 8. Click on the hyperlink to learn more about
this priority area.

Status: Withdrawn

Trends: Eliminate redundant reporting
States' Original Input
Data reporting from the Permit Compliance System (PCS) and the Enforcement and Compliance
History Online (ECHO) is burdensome. It would be more efficient for EPA to pull out the information
directly from the database; instead, states have to report it to the Region in hard copy. (MD)
EPA Response
Region 3 and Maryland are in agreement that no further action is necessary at this time. It was
resolved on a September 2007 conference call during which Maryland indicated that it was not a
concern at present.

Maryland's recommendation refers to the electronic transmission of data through PCS, which is then
displayed on the ECHO Web site. Once Maryland's data system (TEMPO) is technologically capable
of interfacing with EPA's Integrated Compliance Information System (ICIS), which is replacing PCS,
this request may be revisited to ensure that burden has been reduced.
E11: Improve the Wet Weather Initiative

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E12: Eliminate NPDES Semi-Annual Statistical Summary

Priority Area: This recommendation falls under Priority Area 5. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Eliminate redundant reporting
States' Original Input
Eliminate the double violation semi-annual reports. The quarterly non-compliance report can catch
this. (NE)

Eliminate duplicative semi-annual statistical summary report. Same information can be found in
quarterly non-compliance report and in a more meaningful format. (SC)
EPA's Office of Enforcement and Compliance Assurance (OECA) is in the process of developing a
new regulation that will address a number of National Pollutant Discharge Elimination System
(NPDES) enforcement reporting issues. As part of this new rule, OECA plans to propose to eliminate
the requirement that states submit the Semi-Annual Statistical Summary. Currently, OECA projects
the final rule will be published by October 2009. Until the rule becomes effective, the Semi-Annual
Statistical Summary remains as a regulatory requirement.
E13: Eliminate Asbestos Data Report

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate redundant reporting
States' Oriqinal Input
Eliminate annual monitoring report. Same information is submitted via EPA's database. For the

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annual report, state extracts data from EPA database and submits same information via hard-copy
report. (NE)
Region 7 and Nebraska Department of Environmental Quality (NDEQ) reached agreement through
the FY 2008-2009 Air Section 105 grant negotiation process to reduce the hard copy enforcement
action documents that are required to be submitted to Region 7. Commitment 1.15 from NDEQ's
Section 105 work plan says:

"NDEQ will provide EPA with correspondence and information related to NOVs at Class I and
Class II synthetic minor facilities. EPA will provide NDEQ with the same type of information and
correspondence regarding any federal enforcement action at any air facility in the State of
Nebraska, including those under the jurisdiction of the local agencies. It is acceptable to provide
this information either electronically or via hard-copy."

The commitment requests that NDEQ provide notice of violations. It does not specify how. EPA is
happy to receive them by mail or electronically. This is left up to NDEQ on how they will meet the
commitment. To clarify, this commitment does not require a report, but rather a list of notices of
violation issued by NDEQ.

If the Section 105 project officer has not seen a copy of a notice of violation, he or she may request a
copy during monthly conference calls. If the project officer does indeed ask for a copy of a notice of
violation, he or she receives it electronically. Such requests are made only as needed for discussion
purposes with NDEQ on high priority violations.
E15: Streamline AIRS Facility Subsystem (AFS), Air Quality System (AQS), and
Aerometric Information Retrieval System (AIRS)
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Eliminate following AIRS Facility Subsystem (AFS) reporting requirements: 1) stack test review
reporting, 2) Title V annual certification review reporting, and 3) reporting of HPV criteria code,
violating pollutant, and method of violation discovery.#1 and #2 are already reported to EPA. The
value of #3 is unclear and EPA personnel have been unable to explain the value to the state. (IL)

AFS requires an 8-digit identification code for each air emission or regulated facility. The code is
comprised of a state code, a county code, and a 5-digit facility ID number. Currently, the state uses
an Air Quality Control District code (AQCR) in place of the county code. The AQCR has been used
since the late 1970s and some state air quality regulations are AQCR bases. On the other hand,
counties in the state are meaningless and some have been abolished. Therefore, the AQCR has
more meaning than the county. State proposes to delay renumbering of air facilities using county
code until such time as EPA's data system can allow inclusion of both the county code and AQCR.
Expedite the AFS modernization project (currently scheduled to begin in 2008) or allow state to
continue use of AQCR in place of county code until the AFS modernization is complete. (MA)

Air Quality System (AQS)/AFS AIRS is antiquated. Difficult to enter and retrieve information. Many
data elements not used by the state. State maintains its own database for tracking and reporting.
(NV)

Modify the AFS. Use the exact same field names throughout the system. Provide more explanation of
error codes. Streamline the batch file upload process. Change to an XML submittal of AFS batch files

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through the Exchange Network as soon as possible. Improve readability of QA output files. Complete
AFS modernization earlier than 2011. Implement an enterprise architecture approach. Create a
version of the Universal Interface that runs as EPA Headquarters. (OR)
E16: Eliminate Requirement to Submit National Pollutant Discharge Elimination
System (NPDES) Enforcement Documents

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends: Eliminate low-value data requirements
States' Original Input
Eliminate requirement to submit National Pollutant Discharge Elimination System (NPDES)
enforcement documents and associated correspondence as well as NPDES inspection reports.
Provide a provision in the Performance Partnership Agreement (PPA) that state will provide e-copies
of documents for specific cases upon request from Region. (CO)
Current PPAs and original delegations with Region 8 states require Colorado to submit at least part of
their universe of NPDES enforcement documents, correspondence, and inspection reports. But in
FY2008, the Region agreed to reduce reporting by Colorado. Specifically, Colorado will provide a
subset of inspection reports to EPA (reports for majors, concentrated animal feeding operations
(CAFOs), and storm water inspection reports which have been completed by contractors). Other
reports will not be submitted, but will be available for EPA review at the state offices.

Region 8 reviewed reporting requirements in light of the revised National State Review Framework
(SRF) process. Changes to the SRF can be tracked online. Region 8 has issued specific Regional
guidance which reflects the changes.

In May 2008, the Region issued revised PPA guidance to the states for FY 2009. The inspection
reports the Region is requesting through the PPA is dependent on the quality of reports reviewed
through the SRF and end of year reviews for each state. In FY 2009, the Region and Colorado have
agreed to the same subset of inspection reports as in FY2008.
E17: Eliminate Significant Industrial User (SIU) Semi-Annual and Annual
Reports

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Eliminate redundant reporting
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States' Original Inpu.
Eliminate significant industrial user (SIU) semi-annual and annual reports. EPA can generate these
reports from the Integrated Compliance Information System (ICIS). There is no Headquarters
requirement for the report; only a Performance Partnership Grant (PPG) requirement. (NE)
EPA Response
The Nebraska Department of Environmental Quality provided Region 7 with a list of National
Pretreatment Program (NPP) facilities. Subsequently, the Region changed ICIS so that these
facilities are now distinguishable from NPDES permit holders. As of July 2008, the Region has
committed to attempting to run the reports using ICIS as the source.
E18: Eliminate Quarterly Narrative Summary of Compliance Assistance for Non-
Title V Sources
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Eliminate quarterly narrative summary of compliance assistance activities for "conditioned" non-Title
V and synthetic minor sources. (SC)
E19: Reduce Data Required for Resource Conservation and Recovery Act
(RCRA) Enforcement Reporting
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
Reduce the level of reporting by state to be consistent with other states within the Region as well as
nationally. Currently, state must provide copies of all (100%) enforcement and compliance documents
to Region, including inspection reports, enforcement actions, penalty calculations, related
correspondence, sampling data, and settlement documents. (UT)
E20: Eliminate Civil Dockets Reports

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and it taxes their already stressed workload. EPA staff are provided more current information, on a
case-by-case basis, through other channels (e.g., meetings, telephone calls, correspondence). (VA)
E21: Improve Process for Implementing Innovative Programs

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original In
When a state proposes to implement an innovative strategy, EPA requires the state to develop a
baseline even if a similar strategy has been implemented in another state. We understand EPA's
need to measure outcomes, but when such baselines are not required for traditional approaches we
feel that innovative approaches are at a significant disadvantage due to extra reporting and
recordkeeping burdens. (CO)
EPA and states need to create easy, predictable formula for trading resources from traditional to
innovative programs. Creating the "currency" is imperative in order to prevent the application process
from becoming arbitrary and overly burdensome. The formula needs to take into account both the
"environmental footprint" of the sources as well as their environmental performance. Also, EPA and
states needs to clearly articulate end-of-year reporting requirements on the innovation. The
requirements should not be additive and should replace existing requirements to the extent they are
duplicative. (MA)
E22: Improve Award Process for Asbestos Compliance Monitoring Grants

The Region should allocate asbestos grant funds to the state without making the state compete for
each grant. These programs should be treated as core state programs. Grant allocations should be
determined and then the work plan should be negotiated as part of the Performance Partnership
Agreement (PPA). Results should be reported in the PPA End-of-Year Report. Budget reporting
should be part of Performance Partnership Grant (PPG) reporting. (UT)
E23: [Recommendation deleted - same as W28]

In March 2008, EPA released a draft progress report on the Burden Reduction Initiative. The March report is
the first time codes such as "E23" and "W28" were introduced. The same codes are used herein. Because
this report's primary audiences - state and EPA personnel working on the Initiative - are familiar with the
March report, it is important to offer an explanation when a recommendation that was in the previous report
does not appear here. In the case of E23, it was deleted because it was identical to W28.
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E24: Use Performance Partnership Agreements (PPA) for Enforcement
Reporting

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends: Eliminate redundant reporting
States' Original Input
Issues related to enforcement include negotiating multiple agreements, a Performance Partnership
Agreement (PPA), and an inspection agreement. We would ask that EPA attempt to have a single
definitive document if a state has opted to use a PPA. We do appreciate the Office of Enforcement
and Compliance Assurance's (OECA's) willingness to allow the State Review Framework (SRF)
assessments to occur every three years instead of annually for adequate programs. We ask that
Regions not be allowed to request any additional information on compliance programs beyond the
SRF. States are not always comfortable refusing Regions requested information or data. (CO)
EPA Response
Region 8 has tried to meet Colorado's recommendation but cannot fully implement it. The PPA
contains most compliance and enforcement requirements to implement the National Pollutant
Discharge Elimination System (NPDES) program. The Inspection Plan (which contains most of the
inspection program information for NPDES enforcement) was included in the PPA in FY2007. Since
then, the Region has been required to have a Compliance Monitoring Strategy (CMS) - including an
Inspection Plan - for each state and provide a copy to EPA Headquarters. This requirement makes it
impractical to incorporate the CMS into the PPA.

On an ongoing basis, the Region will continue to look for opportunities to incorporate compliance and
enforcement requirements into the PPA. Additional information on compliance programs beyond the
SRF is required in order for EPA to fulfill its ongoing annual oversight responsibilities as required by
regulation at 40 CFR 35.115 and EPA Headquarters national program guidance. The SRF Guidance
itself states that "Regions will continue to conduct mid-year reviews, end-of-year reviews,
management discussions, grant oversight and oversight inspections which are all part of the existing
and ongoing process of oversight."
E25: Reduce Data Required in Used Oil Handler Compliance/ Enforcement

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E26: Reduce Frequency of NPDES Quarterly Non-Compliance Report (QNCR)
Priority Area: This recommendation falls under Priority Area 5. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends: Eliminate redundant reporting
States' Original Input
    Reporting frequency for the NPDES Quarterly Non-compliance Report (QNCR) should be reduced to
    annual. Since this data is stored in ICIS, EPA staff can review it at any frequency determined
    necessary. (IL)
EPA Response
   The QNCR, required by 40 CFR 123.45, lists major facilities that are not complying with their NPDES
   permits. These reports are used by EPA and the states to track progress and assess the
   effectiveness of NPDES compliance monitoring and enforcement activities. EPA has coded both PCS
   and ICIS-NPDES to automatically generate the QNCR each quarter, provided the appropriate
   information is entered into the system by the states. This reduces the burden on states in generating
   the QNCR. EPA will not eliminate the report, however.
E27: Eliminate the Annual Public Water System (PWS) Compliance Report
Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends: Eliminate redundant reporting
States' Original Inpu.
    Eliminate the Annual Public Water System Compliance Report, a summary and detailed list of all
    violations received by any water system. This report can be generated at the EPA Regional level from
    data already provided. (KY)

    Eliminate requirement Annual Compliance Report. The public receives the same  information from the
    public water system when they do the consumer confidence reports. The state receives only one or
    two requests for a copy of this report per year. (ND)
EPA Response
    EPA will not implement Kentucky and North Dakota's recommendations.

    Section 1414(c)(3)(A)(i) of the Safe Drinking Water Act (SDWA) requires that states submit to EPA,
    and states make available to the public, an annual report on violations of national primary drinking
    water regulations by public water systems. Moreover, SDWA Section 1414(c)(3)(A)(ii) requires states
    to publish and distribute summaries of this report. Congress's intent was to ensure that states	
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provide their residents readily available information about the quality of the water they are drinking.

EPA's Office of Enforcement and Compliance Assurance (OECA) summarizes the information from
the state reports and publishes the National Public Water Systems Compliance Report. This report is
also submitted to Congress.

A brief Internet search found that many states post their individual PWS reports on their state Web
sites, as well (e.g., CT, IA, KS, OH, OK, PA, NM, MT, VA). Eliminating these easily accessible
reports would make it more difficult for residents to access information about their drinking water
quality.

While the Agency is not implementing the particular recommendations made by Kentucky and North
Dakota, EPA has already taken considerable steps to reduce states' burden associated with meeting
this statutory obligation:

o Originally, states provided this report in hard-copy, but EPA has been accepting the reports
electronically for a number of years.

o Every year EPA's Office of Ground Water and Drinking Water provides the states with a computer
query that extracts for each state the precise compliance data it needs to prepare its report.

o Also, OECA has provided guidance on how to prepare an effective Annual Report. (The
guidance was distributed to the states with the assistance of the Association of State Drinking
Water Administrators (ASDWA) before the first report was due in October of 1997.)

Ultimately, EPA would like to be able to create the PWS report directly from the Safe Drinking Water
Information System (SDWIS). However, state reporting to SDWIS is not of sufficient quality to allow
that at this time.
E28: [Recommendation deleted - incorporated into E12]

In March 2008, EPA released a draft progress report on the Burden Reduction Initiative. The March report is
the first time codes such as "E28" and "E12" were introduced. The same codes are used herein. Because
this report's primary audiences - state and EPA personnel working on the Initiative - are familiar with the
March report, it is important to offer an explanation when a recommendation that was in the previous report
does not appear here. In the case of E28, it was incorporated into E12 because the South Carolina
recommendation that was originally coded as E28 refers to the same report (the National Pollutant Discharge
Elimination System (NPDES) Semi-Annual Statistical Summary) as the Nebraska recommendation in E12.

E29: Consider State Notices of Violation (NOVs) to be Formal Actions

Priority Area: This recommendation falls under Priority Area 7. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends: Eliminate redundant reporting
States' Original Input
Within fifteen days of the generation of EPA's Quarterly Watch List, state is required to provide an
explanation of why no formal action has been or will be taken, unless an explanation is already
provided on the Quarterly Noncompliance Report (QNCR). EPA should consider state Notices of
Violation (NOVs) as formal actions, given these actions can be appealed. Do not require an
additional report beyond that annotated on the quarterly non-compliance report. (AL)
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EPA Response
EPA does not consider NOVs as formal enforcement actions because most state NOVs under most
state statutes are not enforceable or legally binding. Therefore, explanation of a recognized formal
action is required either as part of the QNCR or in a separate report.
E30: Improve Data Sharing Between State and Federal Enforcement Databases

In August 2007, EPA released its first progress report on the Burden Reduction Initiative. In March 2008,
EPA released a second progress report in draft form only. EPA has tried to maintain consistency between
this progress report and the earlier ones because the primary audiences for this report - state and EPA
personnel working on the Initiative - are familiar with the previous reports. In some instances, however, it
was necessary to deviate from the previous reports. E31 is one of those instances.

E31 was added to this report by separating it from Recommendation E26 - Reduce frequency of National
Pollutant Discharge Elimination System (NPDES) Quarterly Non-compliance Report (QNCR). That is
because Illinois' original state submission recommended that quarterly reporting under NPDES and the Safe
Drinking Water Act (SDWA) should be reduced. Since two separate parts of EPA address NPDES and
SDWA reporting, the original state submission was separated into two recommendations.

E31 is not addressed in this progress report because the report focuses on the 16 priority areas. Still, it is
listed here to ensure that the Agency provides a full list of all states' submissions.
States' Original In
Reporting frequency for the quarterly non-compliance report for SDWA should be reduced to annual.
Since this data is stored in SDWIS, EPA staff can review it at any frequency determined necessary.
(IL)
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Recommendations Related to the Office of Grants &
Debarment (OGD) or Other Cross-Cutting Offices
G1: Reduce Frequency Quality Management Plan (QMP) Revisions

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Original Inp-
Reduce Quality Management Plan (QMP) revisions to once every five years. Use written policy and
Quality Assurance Project Plan (QAPP) to revise day-to-day operations. (IN)
G2: Standardize Records Retention Requirement

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Consolidate Toxic Substances Control Act (TSCA) grant into other, larger grants. State's award for
FFY07 totaled $54,000. It would be administratively efficient to roll the grant into a larger one. This
rationale could be applied to many EPA grants that are small dollar amounts, such as the Resource
Conservation Challenge. (KY)
G4: Streamline Review of Program Guidance, Commitments, and Measures

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
At different points in time, comments are sought from the states on the National Strategic Plan, the
National Program Manager (NPM) Guidance, Regional Work Commitments, and commitment
measures. State recommends (like MA) that EPA identify which goals, commitments, measures,
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and/or strategies for each of these documents are new, revised, or existing from previous years.
Additionally, make all state comments and EPA responses readily transparent. (CT)
At different points in time, comments are sought from the states on the National Strategic Plan, the
NPM Guidance, Regional Work Commitments, and commitment measures. State recommends that
EPA identify which goals, commitments, measures, and/or strategies for each of these documents
are new, revised, or existing from previous years. Additionally, make all state comments and EPA
responses readily transparent. (MA)
G5: Eliminate Reporting on State-Based or Other Programs Not Federally
Funded

Priority Area: This recommendation falls under Priority Area 9. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate low-value data requirements
States' Original Input
The Performance Partnership Grant (PPG) work plan quarterly report is too detailed and extensive.
Eliminate PPG work plan requirements that are related to state-based or other programs not largely
funded by Federal funds. Target the PPG work plan directly on EPA National Performance Measures.
(AZ)
EPA is responding to reporting frequency at a national level. EPA's Office of Grants and Debarment
(OGD) is drafting a grant reporting policy that will apply to all grants and assistance agreements. The
policy limits EPA to a reporting frequency no greater than semi-annual, except in cases of poor
performers, or where Regions and States have otherwise agreed. See Priority Area 9 for more
information about this policy.
Furthermore, Region 9 responded to Arizona's specific request in FY2008. Information from state-
based programs that are not federally funded are not part of the PPG work plan any longer. This
information will be reported as needed by an informal exchange between the state and EPA water
programs.
G6: Reduce PPA/PPG Reporting Frequency

Priority Area: This recommendation falls under Priority Area 9. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Reduce reporting frequency
Return to true multi-year Performance Partnership Agreement (PPA) and eliminate extensive annual

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updates that are now required. (SD)

Combine all reporting for PPA/Performance Partnership Grant (PPG) into one annual progress report
(PPG is required quarterly). (VA)
EPA is crafting a national policy to address grant reporting frequency, among other things. See
Priority Area 9 for more information about this policy.
G7: Reduce Reporting Frequency on Disadvantaged Business Enterprise (DBE)
Utilization

Priority Area: This recommendation falls under Priority Area 11. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends: Reduce reporting frequency
tates' Original Input
Minority Business Enterprise/Women Business Enterprise (MBE/WBE) reports for SRF and
Superfund Grants should be annual rather than quarterly. Annual reports are required for all other
grants and there appears to be little use of the quarterly data. (IL)

Reduce quarterly MBE/WBE report to annual reporting frequency. (IN)

Reduce quarterly MBE/WBE report to annual reporting frequency. (MA)

Reduce reporting frequency to annually or when grant ends for MBE/WBE quarterly reports. Other
entities (educational institutions) are required to file annually. (NE)

Quarterly MBE/WBE reporting is a burden. This is especially so since most EPA funds present no
real opportunity to procure goods and services from women-owned or minority-owned businesses.
Annual reporting should be sufficient. (NH)

Quarterly MBE/WBE reports must be filed for each grant received from EPA. Eliminate this
requirement. It is not required by other Federal grantors such as DOE or DOD. (SC)

EPA grants require the submission of annual or quarterly Minority Business Enterprise/ Women
Business Enterprise (MBE/WBE) utilization reports. Because the majority of EPA funding is used for
personnel costs, many of these reports capture very little useful data. (VA)
EPA Respon
States asked EPA to change Minority Business Enterprise/Women Business Enterprise (MBE/WBE)
reporting requirements by reducing the frequency of reporting from quarterly to annual. EPA's Office
of Small Business Programs (OSBP) responded with a new rule that, among other changes, reduced
quarterly reporting frequency.

The new Disadvantaged Business Enterprises (DBE) Rule took effect on May 27, 2008. The rule
instituted a requirement for semi-annual reporting for any grant or cooperative agreement that
previously required quarterly reporting.

More detailed information about the DBE rulemaking is available in the Priority Area 11 description.
Additionally, you may access the MBE/WBE Reporting Fact Sheet online. It lists which
grants/agreements have a semi-annual reporting frequency and which have an annual frequency.
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Or, you may reference Section III, Part 5 of the preamble to the regulation at 73 FR 15904.
G8: Reducing Reporting Frequency for Smaller Grants and Programs

Priority Area: This recommendation falls under Priority Area 16. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Reduce reporting frequency
States' Original Input
Stop requiring quarterly reporting for smaller grants and programs (e.g., Underground Injection
Control (DIG), pesticides, PCBs, lead, asbestos). (MD)

All reporting for EPA grants should be no greater than annual. For small grants less than $100,000,
reporting should only be required when the grant is completed. (Ml)

All EPA water grant reports should have a nationwide requirement of annual reporting or less
frequent reporting. All grants of $100,000 or less should have a single reporting requirement of a final
report prior to grant closeout. This would save states and EPA significant staff time in preparing and
reviewing reports, since most grants require quarterly or semi-annual reporting. (Wl)
EPA Response
EPA's Office of Grants and Debarment (OGD) is responding by creating an Agency-wide grant
reporting policy. Among other things, this policy will reduce quarterly grant progress reports to a
frequency of no greater than semi-annually, except in instances of poor performers or where Regions
and states have otherwise agreed. Read more about the national grant reporting policy in the Priority
Area 16 overview.
G9: Streamline Performance Partnership Agreement/ Performance Partnership
Grant (PPA/PPG) Reporting Requirements

Priority Area: This recommendation falls under Priority Area 9. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends:
. Eliminate redundant reporting
. Additional resources are needed for additional requirements
States' Original Inpu
If a discretionary grant (e.g., Pollution Prevention Grant [P2 Grant]) is included in a Performance
Partnership Grant (PPG), we ask EPA find a way to merge the application and reporting processes.
Having to annually implement separate grant processes is not worth either EPA or the states' time
and resources. (CO)
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For every new or updated performance measure that must be reported in the Performance
Partnership Agreement (PPA) End-of-Year Report, EPA should be required to reduce a performance
measure unless EPA is providing additional resources. (SD)

State's annual PPA End-of-Year Annual Report should be the only reporting mechanism used to
document the results received for the work plans. All additional quarterly and semi-annual reports
requested by EPA should cease. (UT)

End progress reporting on individual grants that are contained within the PPA/PPG. (VA)
EPA Response
EPA is responding to reporting frequency at a national level. EPA's Office of Grants and Debarment
(OGD) is drafting a grant reporting policy that will apply to all grants and assistance agreements. The
policy limits EPA to a reporting frequency no greater than semi-annual, except in cases of poor
performers or where Regions and states have otherwise agreed. See Priority Area 9 for more
information about this policy.

Further recommendations submitted by the four states were addressed at the Regional level because
every PPA/PPG negotiation between a Region and a state is different. Region 3 responded to
Virginia's recommendation: Starting with the FY2008 grant award, Region 3 requires a semi-annual
"exceptions-only" report and an annual progress report for the PPGs. This was communicated as
part of the grant award process.

Region 8 responded to the recommendations from Colorado, South Dakota, and Utah. Utah's
recommendations will be addressed in the context of the FY 2009 Draft PPA submitted for negotiation
during summer/fall 2008. The magnitude of the new or additional items requested by EPA in the
annual updates comes from both the National Program Manager (NPM) and Region 8 programs. In
addition to these negotiations, when completed, the national grant reporting policy will reduce any of
Utah's quarterly reporting to a semi-annual frequency at most.

On an ongoing basis, Region 8 will continue to look for opportunities to include reporting
requirements in Colorado's PPG.

Furthermore, Region 8 has pledged to South Dakota that it will take steps to control unnecessary
requests each year from the various Region 8 programs and will work to coordinate requests.
G10: Reduce Reporting Frequency for Financial Status Reports (FSRs)

Stop requiring interim FSRs. Not all Federal agencies require them. (MD)
G11: Streamline Cost Estimation Requirements in Grant Applications

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States' Original Input
Water grants (including Sections 106, 319, 104(b)(3), 104(g), wetlands, etc.) require detailed
explanations for travel, supplies, and other categories in EPA grant applications. Eliminate these
requirements. We should be accountable forspending grant funds properly, but not be detailing
travel, supplies, and the like in grant applications when we can only estimate our needs. (Wl)
G12: Streamline Certification and Assurance Requirements for Grant
Applications
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Inpu
Reinstitute annual submission of Grant Consolidated Certification and Assurance Program, rather
than requiring these forms grant-by-grant during application process. (MD)
Each grant application requires certifications (1. Debarment, Suspension, and other Responsibility
Matters, 2. Drug-Free Workplace Act of 1988, 3. Lobbying, 4. Procurement System (Superfund only),
and 5. SF 424B Assurances) and a report (EPA Form 4700-4 Annual Pre-Award Compliance Review
Report. Allow state to batch the certifications and report for each grant into a single annual
certification. (TX)

Each EPA grant application requires "Certification Regarding Lobbying" and "Assurances - Non
Construction Programs" statements. This is an unnecessary duplication of paper. Documentation
could be equally well-served by an annual blanket assurance from the state to EPA. (VA)
G13: Eliminate Federal Cast Transaction Reports

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States' Original Input
For Superfund, allow 60 days to report after the quarter rather than 30. (MD)
Quarterly reports for Superfund and Brownfields Cooperative Agreements and Grants are due within
30 days after the end of the quarter. Fiscal/budget information, which makes up part of the report, is
often not available within the 30-day period resulting in incomplete reports or late reports. Move this
deadline from 30 days after the end of the quarter to 60 days. (MA)
G15: Streamline Reporting on Financial Draw Requests
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
When state enter financial "draw requests" into ASAP database, ask for less information. Stop
requiring tracking by individual sites or other such specific categories. Only require draw requests at
the grant number or higher. (MD)
G16: Reduce Data Elements and Eliminate Redundancy in Quality Assurance
Project Plans (QAPPs)
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Oriainal Incut
The state submits numerous Quality Assurance Project Plans (QAPPs) for each project. There is a
large amount of overlap among each QAPP. Many individual projects could be covered under one
"umbrella" QAPP. Then, any special items could be covered as an addendum to the "umbrella."
Furthermore, EPA should develop a QAPP template for each project after a work plan is approved.
This would help this states know exactly what EPA expects in the QAPPs and decrease the 12- to 24-
month review and approval time frame. Finally, allow the state to reference the work plan whenever a
QAPP requires redundant information rather than having to cut and paste the information in the
QAPP. (AR)

Revisit increasing and expanding quality assurance requirements in programs in addition to the water
program. (MD)

The purpose of Secondary Data QAPPs is to document the quality of second generation data which
can/will be used to make decisions. (OK)
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G17: Reduce Data Elements Required in Federal Databases to Make Data
Synchronization Easier
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Implement EPA's data warehouse strategy, holding only high-level data needed for Headquarters
program analyses. Collect only summary data in Federal systems (systems include Permit
Compliance System (PCS), AIRS Facility Subsystem (AFS), and RCRAInfo) and allow states to
"publish" the supporting detail—accessed on demand by EPA, but not stored in EPA systems. This
will eliminate all issues related to synchronizing the data sets. (OR)
G18: Share Grant Award Information among Databases [newly added]

In August 2007, EPA released its first progress report on this Burden Reduction Initiative. In March 2008,
EPA released a second progress report in draft form only. The Agency has tried to maintain consistency
between this progress report and the earlier ones because the primary audiences for this report - state and
EPA personnel working on the Initiative - are familiar with the previous reports. In some instances, however,
it was necessary to deviate from the previous reports. G18 is one of those instances.

G18 was added to this report after not appearing in a previous progress report. That is because the original
state submission did not fit under any of the existing recommendations. G18 is not addressed in this
progress report because the report focuses on the 16 priority areas. Still, it is listed here to ensure that the
Agency provides a full list of all states' submissions.
States' Original Inpu.
Improve information sharing about grant awards so that the ASAP system is automatically informed
about awards and amendments, rather than requiring the grantees (i.e., states) to tell ASAP staff.
(MD)
G19: Determine Indirect Rates More Promptly [newly added]

G19 was added to this report after not appearing in a previous progress report. That is because the original
state submission did not fit under any of the existing recommendations. G19 is not addressed in this
progress report because the report focuses on the 16 priority areas. Still, it is listed here to ensure that the
Agency provides a full list of all states' submissions.
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States' Original Inpiu
    Find ways to establish indirect rates more promptly. The indirect rate is often late being determined
    which makes us late reporting, because we can't figure our personnel costs accurately without the
    indirect rate. (MD)
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Recommendations Related to the Office of Prevention,
Pesticides, & Toxic Substances (OPPTS)

P1: Improve Award Process for Pollution Prevention Grants
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Oriainal Irmu
Pollution prevention (P2) grants - EPA continues to have a competitive grant process for states with
an excellent track record, which have received such grants for over a decade. States do not think
they should still compete for these grants. (MD)

The Region should allocate P2 grant funds to the state without making the state compete for each
grant. These programs should be treated as core state programs. Grant allocations should be
determined and then the work plan should be negotiated as part of the Performance Partnership
Agreement (PPA). Results should be reported in the PPA End-of-Year Report. Budget reporting
should be part of Performance Partnership Grant (PPG) reporting. (UT)
P2: Reduce Reporting Frequency of Pollution Prevention Semi-Annual Reports

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Pollution prevention semi-annual reports are designed to document project activities and
expenditures during each half of the grant period. The frequency of reporting seems unnecessary at
times because the nature of the projects being completed typically requires several months and often
there are periods in which little or no measurable activities occur (e.g., waiting for contractual sub-
agreement development and execution). Reduce reporting frequency to an end-of-grant report. (FL)

State recommends a progress/ status report at the end of the first year of the grant, rather than semi-
annually. By then partnerships have been established, baseline measurement has been
documented, publications are drafted or published, and strategies are implemented. (NH)
P3: Improve Award Process for Lead Program Grants

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States' Original Input
    Lead grants - EPA continues to have a competitive grant process for states with an excellent track
    record, which have received such grants for over a decade. States do not think they should still
    compete for these grants. (MD)

    The Region should allocate lead grant funds to the state without making the state compete for each
    grant. These programs should be  treated as core state programs. Grant allocations should be
    determined and then the work plan should be negotiated as part of the Performance Partnership
    Agreement (PPA). Results should be reported in the PPA End-of-Year Report. Budget reporting
    should be part of Performance Partnership Grant (PPG) reporting. (UT)
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Recommendations Related to the Office of Solid Waste
& Emergency Response (OSWER)

SW1: Reduce Frequency of Superfund Reporting
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Original Input
Reduce quarterly reporting of National Priorities List (NPL) oversight activities to annual reporting.
(AL)
Reduce frequency of quarterly Superfund Site Assessment reports to semi-annual reporting. The
frequency of reporting seems unnecessary at times because the nature of the projects being
completed typically requires several months and often there are periods in which little or no
measurable activities occur (i.e., waiting for analytical data, site access delays, and issuing work
plans and/or reports for high public interest sites where multiple parties are involved). (FL)

Change frequency of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERLA) Preliminary Assessment/ Site Inspection (PA/SI) grant reporting from quarterly to semi-
annually. The sites in this program tend to be much longer-term sites and, as such, little or no result
can be demonstrated in a quarter. (KY)
SW2: Streamline Hazardous Waste Year-End Report
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Inpiu
The need to summarize accomplishments and document accountability will never, and should
never go away. The means of doing so may be streamlined by going from a printed Hazardous
Waste Year-End Report to a totally electronic format. In addition, because EPA also conducts an
assessment regarding the state's activities, one streamlining option would be for EPA and the
state to prepare a joint year-end report. (SD)
SW3: Eliminate Requirement to Report Jobs Created Under Brownfield
Response Program
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
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States' Original Input
Brownfields: Modify burdensome requirement to determine how many new jobs will be created as a
result of a project. We have to rely on facilities for this information and can't reliably verify their
accuracy. (MD)

Quarterly Property Profile Forms for the Brownfield Response Program should be modified to
eliminate performance measures that are difficult to obtain (e.g., average jobs created). Find more
useful performance measures that are more easily obtained. (VT)
SW4: Streamline Hazardous Waste Program Authorization Updates

The RCRAInfo corrective action/permitting module is a burden because of the time it takes to enter
data. RCRAInfo has a very poor user interface and data entry requires the use of EPA codes which
are confusing to the state and often require direct communication with our EPA contact to help
identify the correct code to use. 1) Improve the user interface. 2) Reduce the number of corrective
action codes or have EPA staff enter this data. 3) Minimize the investment of time needed to test and
modify translators in the compliance module. (OR)

Eliminate requests to provide reports that can be generated from data available in RCRAInfo. (SC)
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SW6: Streamline Underground Storage Tank (LIST) Reporting

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Inpu
The State Underground Storage Tank (UST) Data Form is required as a Leaking Underground
Storage Tank (LUST) grant condition. This form is so complex that it takes two months to
complete. Simplify the form and greatly reduce the data requested. Furthermore, it is redundant
with state financial reports. Suggest that reporting be limited to monthly cash balance once a
quarter (vs. dated annual report) with the option to request more detailed report when cash
balance shows significant decreasing trend. (ME)
SW7: Streamline Underground Storage Tank (UST) Reporting Quality
Assurance Project Plans (QAPPs)
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
One Quality Assurance Project Plan (QAPP) is required for each Leaking Underground Storage
Tank (LUST) Trust funded site (currently 34 in the state) and for each Brownfield/Underground
Storage Tank (UST)-field funded project. Allow an umbrella QAPP plan for UST release sites
with a minimal amount of site-specific information added as needed. Allow states to take
advantage of procedures already developed and proven (e.g., Standard Operating Procedures
(SOP), Quality Management Plan). Work with the state to think through how to implement each
QAPP requirement prior to placing the requirement in a work plan with deadlines and
consequences. (SC)
SW8: Eliminate the End-of-Year Clean Air Act (CAA) Section 112(r) Report

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SW9: Streamline Hazardous Waste Reporting on large Quantity Generators and
Treatment, Storage, or Disposal (TSD) Facilities
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Biennial Reports are required from all Large Quantity Generators and Treatment, Storage, or
Disposal (TSD) facilities. The reports show the quantities, and description of hazardous waste
generated in the reporting cycle. The reports are not very useful. By the time EPA loads the
Biennial Reports into RCRAInfo, the data is old and often data cleanup is necessary to accurately
reflect the facilities' generator status. Some other method needs to be developed to streamline
the input of data (e.g., facilities could directly input their data into EPA's system). Or, replace the
Biennial Report collection process altogether perhaps with an e-manifest system where facilities
report their hazardous waste data directly into an EPA e-manifest system. (NE)
SW10: Reduce Data Elements Required for the Resource Conservation and
Recovery Act (RCRA) State Hazardous Waste Management Grant and the State
Underground Storage Tank Trust Fund Grant Reporting
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
The main objectives of the Resource Conservation and Recovery Act (RCRA) State Hazardous
Waste Management Grant and the State Underground Storage Tank Trust Fund Grant programs
are embodied in the Government Performance & Results Act (GPRA) goals of controlling human
exposures and controlling groundwater releases. All other bean counting should be eliminated
because it adds little or no value to the mission. (KY)
SW11: Consolidate Hazardous Waste Program Reporting

This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
In the Hazardous Waste Program, there are five major reporting burdens: Biennial Report, Mid-
Year Resource Conservation and Recovery Act (RCRA) C Grant Report, End-of-Year RCRA C
Grant Report, RCRAInfo, and Monthly Permit Summary. While important, these required reports
are time-consuming to prepare. EPA should consider how to consolidate reports. (MD)
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SW12: Reduce Reporting Frequency for Underground Storage Tanks (LIST) and
Leaking Underground Storage Tanks (LUST)
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Change reporting frequency for Underground Storage Tank (UST) and Leaking Underground Storage
Tanks (LUST) grants from semi-annual to annual. (DE)

Draft "Grant Guidelines to States for Implementing the Public Record Provision of the Energy Policy
Act of 2005" are redundant with existing (and more effective) state procedures to inform public of
local UST discharges. Compliance and other data requested already provided to EPA every six
months as part of other reporting requirements for the Leaking Underground Storage Tank (LUST)
trust grants. EPA should use existing data to create national Web site to meet Energy Policy Act.
(ME)

EPA has imposed several initiatives and projects on the Oil Control Program, in addition to other
existing deliverables, that are time-consuming, resource-intensive, and without additional funding.
They should be reconsidered. They are: 1) report level of compliance on all active USTs, 2) report
items that fail inspection, 3) report source of releases into groundwater, and 4) report status on all
government tanks. (MD)
SW13: Increase Reporting Flexibility for Hazardous Waste Small Business
Compliance Assistance Program [newly added]

SW13 was added to this report by separating it from Recommendation G9 - Streamline Performance
Partnership Agreement / Performance Partnership Grant (PPA/PPG) reporting requirements. That is
because the original state submission below is a separate recommendation from the others found in G9.

SW13 is not addressed in this progress report because the report focuses on the 16 priority areas. Still, it is
listed here to ensure that the Agency provides a full list of all states' submissions.
States' Original Input
EPA expects all facilities, regardless of size, to conform to identical requirements without
consideration of the comparative risks and available resources. EPA should allow more
reasonable flexibility to the state in the administration of the small business compliance
assistance program. State should not have to manage small businesses in the same manner as
large quantity hazardous waste generators. (UT)
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Recommendations Related to the Office of Water (OW)

W1: Streamline Reporting In or Related To Safe Drinking Water Information
System (SDWIS)

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Streamline databases
States' Original Input
Strategic plan measures and target data is already reported in the Safe Drinking Water Information
System (SDWIS) by states. EPA should use the data in SDWIS to evaluate against strategic plan
measures and target data (MA).

States should not be required to re-verify data in SDWIS. Since SDWIS is the official reporting
database, data in it should be recognized as up-to-date and reliable and the primary source of data.
Verification is a duplication of effort and is unnecessary (MA).

Modify SDWIS Fed to extract from SDWIS State. The quarterly SDWIS State uploads contain the
most current data available to the state and requiring states to duplicate the effort is burdensome
(MT).

FY07 Grants Linked to Performance, Public Water Annual Compliance Report, and Strategic
Performance Measures: This report, requiring a query of SDWIS State, resulted in a number of days
of staff time. Finally we had to hire a consultant to perform the query for us. SDWIS Fed should be
modified to extract this data so that states don't have to spend time and precious funds procuring
data that should be available to EPA. If this is found to be necessary in the future, why not at least
provide states with a ready-made SDWIS query? (MT)

Use SDWIS State to track electronically: inventory data, technical assistance/customer service, TCR
data, source water assessment and protection data, and completed reports/letters. Monthly
deliverables from each team presented in hard copies are burdensome and time consuming (TX).
EPA Respons-
Using SDWIS to evaluate strategic plan measures and target data - All but two Public Water
System Supervision (PWSS)-related strategic plan measures are calculated using data in SDWIS-
Fed. The exceptions include:
o SP-4, which measures the percent of the population served by Community Water Systems where
risk to public health is minimized by source water protection. EPA is in the process of adding a
data element into SDWIS-State and SDWIS-Fed which will enable this measure to be calculated
by EPA. It will be available in 2008.
o SP-5 measures the number of homes on tribal lands lacking access to safe drinking water. Since
EPA and other Federal agencies run this program, it is not a state burden reduction issue.
o States also used to have to report whether they completed their sanitary survey requirements, for
National Water Program Guidance measures SDWIa and b. Starting in 2008, sanitary surveys
are required to be reported in SDWIS-Fed, and EPA will calculate them. However, states are still
required to account for outstanding performers on a longer 5-year cycle. EPA will raise this as an
action to be considered by the SDWIS Data Sharing Committee made up of states and EPA,

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whether to add this data element to SDWIS-State and SDWIS-Fed. More information on strategic
plan measures can be found in the FY-09 National Water Program Guidance and related
appendices.

Using SDWIS to verify data input - Occasionally, verifications are necessary to ensure data quality.
OW infrequently asks states to verify inventory data, primarily information for national surveys such
as the Drinking Water Needs Survey, approximately every 4 years. Additionally, states are also asked
to verify data in the Clean Watershed Needs Survey at the same frequency as previous survey, but
offset by approximately 2 years on a separate schedule.

Extract from SDWIS State - SDWIS-Fed currently extracts data from SDWIS-State on a quarterly
basis. In the modernized SDWIS-Fed, which was implemented in January 2006, the data of record
shifted from production data, which can change at any time, to quarterly frozen data. This lowers
burden and increases data quality.

Annual Compliance Report from SDWIS Query - EPA has modified the query function and created
a standard report that generates data necessary to prepare the Annual Compliance Report.

Using SDWIS to extract a variety of data electronically - Texas requested that SDWIS-State be
used to track the following data electronically: inventory data, technical assistance/customer service,
TCR data, source water assessment and protection data, and completed reports/letters. This will be
completed in 2008. SDWIS-State currently tracks each of these things except source water elements.
EPA is planning to add a source water assessment data field in SDWIS-State and SDWIS-Fed, which
will be ready in 2008.
W2: Eliminate Requirement to Report New Systems in Significant
Noncompliance
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by the Environmental Council of the States (EGOS) in summer 2007 and this
recommendation is not in a priority area. But, it is listed here to ensure that a full list of all states'
submissions is provided.
States' Original Input
States are required to develop a list of new systems within the past three years and identify if those
systems have any Significant Non-Compliers (SNCs) for the capacity annual report. EPA should
generate the capacity report instead of requiring states to develop it. (MA)
W3: Streamline Significant Noncompliance Reporting in Safe Drinking Water
Information System (SDWIS)

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Streamline databases
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States' Original Input
EPA sends us the Public Water System (PWS) quarterly non-compliance report printed from the Safe
Drinking Water Information System (SDWIS) and we have to correct it for them and mail it back. EPA
should fix the database so the data we put in it is the correct data (IA).

EPA should develop an electronic reporting mechanism to report those reasons for non-compliance
within SDWIS-State and SDWIS-Fed. This would also increase automation of the majority of the
capacity development reporting (MA).

Provide SNC determinations through SDWIS State software module in order for state to perform
quality control on data on a continuing basis, before the region asks for Capacity Development
significant non-compliance (SNC) Report (TX).
EPA Response
Correcting PWS quarterly non-compliance reports - EPA believes that the 2006 updates made to
SDWIS-Fed have significantly corrected errors in the Public Water System (PWS) quarterly
noncompliance reports. The Performance Partnership Grant (PPG) between Region 7 and Iowa
currently asks the state to submit data using SDWIS-State 8.0 on a quarterly basis for violations,
enforcement actions, and milestones.

Electronic reporting mechanism - Relative to the capacity development reports, EPA now
generates the historical significant non-complier (HSNC) list every three years (as required) for
states. EPA also generates the list of new systems in significant non-compliance (SNC), but requires
states to tell EPA why each system is on the list. EPA plans to discuss with the Data Sharing
Committee whether SDWIS is an appropriate repository for SNC lists.

Provide SNC determinations through SDWIS-State - EPA is currently moving from a rule-based
significant noncompliance (SNC) determination to one that is system-based. This electronic data
verification tool, or SNC desktop calculator, will allow states to make compliance determinations. The
SNC desktop calculator is in pilot phase and will continue to be tested with a joint EPA-Association of
State Drinking Water Administrators (ASDWA) workgroup through FY-09. After the pilot phase has
ended, EPA will revisit whether to implement a state version of the tool in SDWIS-State. More
information on the pilot is available online.
W4: Eliminate Quarterly Electronic Permit Issuing Forecasting Tool (E-PIFT)
Report

Priority Area: This recommendation falls under Priority Area 5. Click on the hyperlink to learn more about
this priority area.

Status: Implemented In Part

Trends: Eliminate redundant reporting
States' Original Input
Eliminate the Electronic Permit Issuing Forecasting Tool (E-PIFT) record permit backlog quarterly
report. Duplication of information currently available in Permit Compliance System (PCS). (MN)

Quarterly submission of E-PIFT report should be eliminated because Region already checks PCS
and performs a monthly update of the backlogged National Pollutant Discharge Elimination System
(NPDES) permits. State could continue to inform Region when new general permits are issued and
provide number of coverage under general permits on some reduced frequency (twice/year). (MS)
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Eliminate permit counts, backlog, and permit forecast statistics report. Information uploaded weekly
in PCS should be adequate, or else change the expectations for what should be in PCS. (SC)
EPA Respon
The Electronic Permit Issuing Forecasting Tool (E-PIFT) has been replaced by the Permits
Management Oversight System (PMOS). PMOS ensures that data is not duplicative with the Permit
Compliance System (PCS). If a state provides accurate and complete information in either PCS or the
Integrated Compliance Information System for NPDES (ICIS-NPDES), no reporting in PMOS is
needed. Facilities covered under general permits generally are not entered in PCS, however. PMOS
captures that information.

Individuals can search for their individual states' Clean Water Act data information. This information
is displayed in the Enforcement and Compliance History Online (ECHO) system and is fed from either
PCS or from ICIS-NPDES. Please note that ICIS-NPDES is gradually replacing PCS.
W5: Reduce Frequency for Wetlands Pilot Demonstration (WPD) Grant
Reporting
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Funds under the 104(b)(3) Wetlands Pilot Demonstration (WPD) grant are received through the
state's Performance Partnership Grant (PPG), therefore regular updates are already provided as part
of the Performance Partnership Agreement (PPA). Yet, EPA requires three levels of reporting: PPA
status report, quarterly reports WPD reports, and an annual WPD report. Requirements are
duplicative and confusing. Require one annual report in a standard format. (ME)
Reduce quarterly reporting for the Wetlands 104(b)(3) grant to annual reporting. It would be more
efficient to incorporate this reporting as part of the PPA annual report. (Rl)
W6: Eliminate Storm Sewer Overflow (SSO) Reporting
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
.tates' Original Input
Region requires state to continue to implement Storm Sewer Overflow (SSO) strategy and report
annually on its status. State is unclear as to the strategy's purpose since SSO strategies are not
required by Federal law or regulation. State has developed an internal strategy and continues to work
with National Pollutant Discharge Elimination system (NPDES) permittees. EPA appears to be trying
to direct state efforts by requiring detailed reporting. Eliminate this requirement. It far exceeds
reporting necessary to comply with National Program Manager (NPM) measures. (KS)
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W7: Improve Web-Based Research Indexing Tool for Watershed Assessment,
Tracking and Environmental Results (WebRIT)
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Upgrade Web-Based Research Indexing Tool for Watershed Assessment, Tracking and
Environmental Results (WebRIT) to a common program (e.g., ArcView) to allow data transfers in a
more efficient and effective manner. (DE)
W8: Change Deadline for Clean Water State Revolving Fund (SRF) Annual
Report
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
The due date for the Clean Water State Revolving Fund NIMS annual report should be revised to the
end of the calendar year to compensate for adjusting and closing accounting entries completed at the
end of the state fiscal year. This will eliminate time intensive revisions once accurate data is available.
(UT)
W9: Eliminate the Permitting for Environmental Results (PERs) Report

Eliminate PERs and associated reporting. The report lists the permits that have been issued from the
PERs list. EPA requires quarterly reports but calls for updates all the time and before the report is
due. State has an effective permit priority system and PERs is duplicative. (NE)
W10: Modify Reporting Requirements on Publicly Owned Treatment Works
(POTWs) Reusing Biosolids
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This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
aies urigmai mpu
State required to provide the percentage of mechanical Publically Owned Treatment Works (POTWs)
that are beneficially reusing all or a part of their biosolids and, where data exists, the percentage of
biosolids generated that are beneficially used annually. Modify this requirement to only require the
percent of biosolids beneficially reused /fthose data are utilized in a valuable manner. If it is not, drop
reporting altogether. (KS)
W11: Reduce Requirements under the Water Quality Monitoring Plan and
Restoration Schedule
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
State is required to develop a statewide monitoring plan that now has a water quality restoration
schedule associated with that monitoring plan. State developed this monitoring plan, as required.
Now, an additional requirement has been established to achieve water quality restoration results
within a ten-year timeline while reporting progress. Do not require achievement of water quality
restoration results within the established schedule. (MA)
W12: Reduce Frequency for Arsenic Compliance Reporting

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mail contract work orders every six months. Information is already provided to EPA through two
summary documents that identify where the 106 funds are going. After review of the summaries, EPA
could review detailed information of projects when it conducts semi-annual audits of the TMDL
program. (TX)
W14: Eliminate Total Maximum Daily Load (TMDL) Quality Assurance Project
Plan (QAPP) Summary Report
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Region requires state to take information already in the EPA-funded project Quality Assurance
Project Plans (QAPPs) and prepare a summary report of funding source information. The summary
provides a running list of funding sources for every impaired segment in the state that has an
approved EPA QAPP. Conversations with Regional staff seem to confirm that the summary is not
used. Eliminate the duplication. (TX)
W15: Eliminate Annual Summary of Clean Water Act (CWA) Section 106 and
319 Quarterly Reports

Priority Area: This recommendation falls under Priority Area 10. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate redundant reporting
States' Original In
For the National Pollutant Discharge Elimination System (NPDES)/106 and 319, program report
activities quarterly, yet states are also required to do an annual report that summarizes quarterly
reports. This duplication should be reconsidered. (MD)
EPA Respons
EPA's response to Maryland's recommendations is twofold. At the national level, EPA's Office of
Grants and Debarment (OGD) is responding by creating an Agency-wide grant reporting policy.
Among other things, this policy will reduce quarterly grant progress reports to a frequency of no
greater than semi-annually, except in instances of poor performers or where Regions and states have
otherwise agreed. In the case of Section 319, OGD expects that the policy will reduce reporting to an
annual frequency. Read more about the national grant reporting policy in the Priority Area 10
overview

In addition to this national grant reporting policy, Region 3 responded to Maryland's recommendation.
Region 3 clarified in the FY2008 grant work plan negotiation process that states no longer need to
provide an annual summary of NPDES 106 quarterly reports. Furthermore, the Section 319 program
does not require an annual summary of quarterly reports
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W16: Keep CWA Sections 303(d) and 305(b) Reports Separate

Priority Area: This recommendation falls under Priority Area 3. Click on the hyperlink to learn more about
this priority area.

Status: Withdrawn

Trends: Change reporting deadlines
States' Original Inpu.
Allow states to keep 303(d) and 305(b) reports separate if it makes compliance easier. (MS)
EPA Respons
Sections 303(d), 305(b), and 314 of the Clean Water Act (CWA) require states, territories, and
authorized tribes to provide biennial reports to EPA on the condition of waters within their boundaries.
EPA provides guidance on integrated these reports in a way that supports the agency's strategy for
achieving a broad-scale, national inventory of water quality conditions. The guidance is from EPA for
states, territories, authorized tribes, and interstate commissions ("jurisdictions") that help states
prepare and submit Section 305(b) reports to EPA. Use of the integrated report (IR) format provides
jurisdictions a recommended reporting format and suggested content to be used in developing a
single document that integrates the reporting requirements of Sections 303(d), 305(b), and 314. Use
of the IR format allows jurisdictions to report the water quality standards attainment status of all
waters, document the availability of data and information for each segment, identify certain trends in
the water quality conditions, and provide information to managers in setting priorities for future actions
to protect and restore the health of our nation's aquatic resources.

At a March 2007 meeting between EPA Region 4 and AL, FL, GA, KY, MS, NC, SC, and TN, Region
4 informed MS and other Region 4 states that states are not required by statute or regulation to
submit the single, integrated report. However, EPA strongly encourages states to adopt an IR format
to facilitate data compilation and comparisons. MS indicated that despite concerns, it intends to use
the IR format.
W17: Streamline Underground Injection Control (UIC) Reports

Priority Area: This recommendation falls under Priority Area 12. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Reduce reporting frequency
. Streamline databases
. Eliminate low-value data requirements
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States' Original Inpiu
The purpose of the Program Activity Measures (PAMs) is to allow EPA to focus Underground
Injection Control (DIG) program priorities on SWP areas to address potential vulnerabilities. The
problem is that this reporting is duplicating the reporting requirements of the DIG program 7520 forms
(AR).
Reduce DIG reporting frequency from semi-annual to annual. This is a relatively small grant included
in the Performance Partnership Grant (PPG) that has a reporting frequency that is disproportionate to
the purpose of the grant and nature of the environmental problem it is intended to address. It is not
clear that EPA relies on these reports to manage their programs. If the purpose of the reporting is to
ensure progress and accountability on behalf of states, then an annual report should be sufficient
(CT).

Within the DIG program, states provide information on specific well types (motor vehicle waste
disposal wells) as well as a pending future requirement to make the state's inventory available to
EPA. The state's data system does not easily allow for such specified information to be easily
extracted. This information must be manually researched and reported, which results in a significant
burden to the state. This reporting requirement should be eliminated (MA).

DIG Measures Report Form and Quarterly 7520 forms: This relatively small grant is included in the
PPG, but must report separately in addition. It is not apparent that the information used in the
quarterly reports is used for any program or grant management purpose. The reporting could wait
until the FY end to submit final numbers, as part of the Performance Partnership Agreement (PPA)
process. Since ME is only 80% funded by EPA and program costs are offset with oversight of
additional programs, staff time spent responding to additional reporting requirements takes a
disproportionately large share of grant resources (ME).

Switch from quarterly to annual reporting for the DIG Program - it would be more efficient to
incorporate this reporting as part of the PPA annual report the state provides to EPA (Rl).

Reporting burdens should be limited to those provided in the DIG regulations (40 CFR 144.8). A
significant part of the overall DIG reporting burden comes from having a confusing number of
reporting systems and timeframes in addition to the Section 144.8 requirements. A single reporting
system and timeframe would greatly help to achieve burden reduction. Any forms for reporting should
be designed to facilitate reporting of data required under 144.8, rather than imposing additional
requirements beyond those of Section 144.8 (TX).

Follow federal regulations at 40 CFR 144.8. Discontinue requirement of well inventories as a separate
report to EPA; the regulations indicate that an updated well inventory is part of the annual report due
by the 60th day after the end of the calendar year (TX).

Redesign form 7520 with data fields and submittal schedule to facilitate quarterly and annual reports
as required by 40 CFR 144.8. Given that the DIG program is chronically under-funded, the
requirement is burdensome because it is not specified in a federal regulation and requires significant
resources to compile the data and submit to EPA (TX).

Base Program Activity Measures (PAMs) and other reporting requirements in 40 CFR 144.8, and
develop a single reporting system and schedule to facilitate compliance with the reporting
requirements. Activities measured by PAMs must be regulation based and within the capability of the
program under present resource/funding levels (TX).
EPA Resoonse
The Office of Water's (OW) Ground Water and Drinking Water office (OGWDW) agrees that the
information in the Program Activity Measure (PAM) reporting duplicates in part the 7520 reporting
forms on Underground Injection Control (DIG) programs. The agency's solution is the creation of a
new central DIG database, which was launched in December 2007.
EPA believes it is critical to build its capacity to access DIG well-specific information that is efficient,
accurate and usable. Once fully populated, the database will be used to respond to information

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requests from EPA management, Congress, and other governmental leaders and the public.
Additionally, with the DIG program beginning its critical efforts to develop a national regulation for
geological sequestration, EPA will need information that can be centrally housed in the database to
oversee sequestration activities.

Testing and implementation of the new DIG database is currently underway.
W18: Modify CWA Section 319 Grant Reporting and Tracking System (CRTS)

Priority Area: This recommendation falls under Priority Area 10. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Reduce reporting frequency
. Eliminate redundant reporting
. Eliminate low-value data requirements
States' Original Input
Section 319 Grant Reporting and Tracking System (CRTS) - Modify CRTS so that data can be
uploaded from a spreadsheet, database or text file in addition to being entered manually. Should also
provide for a file structure that can accommodate images in the appended text files so that figures
and photos don't need to be stripped out of reports. (MD)

The new mid-year CRTS report for 319 implementation projects should remain on an annual
frequency at most. (MA)

EPA should provide guidance on the Annual Financial Status Reports (FSR) on 319 grants.
Guidance should explain level of detail needed. There seems to be significant differences in the level
of reporting needed to satisfy different EPA staff persons. (MT)

After 10+ years of development, the quantity, quality, and utility of the data in CRTS needs to be
evaluated. Simplify data entry, minimize data input requirements, and eliminate unnecessary/
redundant data. (Note: North Dakota submitted very detailed comments to accompany this
recommendation.) (ND)
EPA Response
EPA's response to the states' recommendations is threefold.

o At the national level, EPA's Office of Grants and Debarment (OGD) is responding by creating an
Agency-wide grant reporting policy. Among other things, this policy will:
1. Reduce quarterly grant progress reports to a frequency of no greater than semi-annually,
except in instances of poor performers or where Regions and states have otherwise agreed.
In the case of Section 319, OGD expects that the policy will reduce reporting to an annual
frequency.
2. Reduce financial status reporting requirements to no more than annually.

o A XML upload process was released July 7, 2008, which addresses Maryland's recommendation.
This upload process allows states to assemble CRTS data without being logged on. States can
then log on and upload files to CRTS directly. This process cuts down on wait time and slow
server issues which can occur if entering data one field at a time. In addition, CRTS recently
migrated to an Oracle-based database which streamlines data entry and minimizes server issues.
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Because EPA Regions play such an active role in Section 319 grant awards and reporting,
Regions also responded to some of the states' recommendations. Region 1 responded to
Massachusetts' request to reduce Section 319 implementation projects reporting to annually.
Region 1 confirmed that the implementation projects report is only required annually; the due date
is February 15th for all states in the Region. Finally, Region 8 is working with Montana and North
Dakota to reduce CRTS reporting burden.
W19: Eliminate Report on Permits Issued Per Watershed

Clean Water Act (CWA) Sections 106 and 604(b) work plans require a narrative description of tasks
that will be undertaken. Status reports require the compilation of work completed by state and often
the work of contract staff. Utilize the spreadsheet format currently employed for the status reports as
the base document for the work plans. (PA)
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W22: Streamline Nonpoint Source (NPS) Report

Priority Area: This recommendation falls under Priority Area 4. Click on the hyperlink to learn more about
this priority area.

Status: Implemented

Trends: Eliminate low-value data requirements
States' Original Input
Nonpoint Source Annual Report under Clean water Act (CWA) Section 319: Streamline preparation of
report and eliminate the requirement of a "glossy" report. It is not widely used by the state and the
"glossy" report is expensive to print. (OK)
After EPA received this submission from the State of Oklahoma in 2006, Region 6 clarified that its
states are asked to provide a single report on CWA 319 program activities, which is due at the end of
each January. These reports have been streamlined in recent years from 150-250 pages to 20-40
pages and a glossy report is not required. Region 6 will continue to work with OK on CWA 319
program reporting to ensure it meets all statutory and regulatory requirements without being overly
burdensome.

Oklahoma has since indicated that it has implemented this streamlining measure without further
concerns about report length. Based on recent annual report submittals to Region 6, it is clear that
other states are following suit and preparing shorter, more concise reports. In addition, Region 6
responds to each state annual report submittal to provide programmatic feedback and direction.
W23: Reduce Reporting on Draft Major and Minor National Pollutant Discharge
Elimination System (NPDES) Permits

Priority Area: This recommendation falls under Priority Area 5. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Eliminate low-value data requirements
States' Original Input
Eliminate requirement to notify EPA of all National Pollutant Discharge Elimination System (NPDES)
permits that state intends to issues, reissue, or modify within next 12 months on 303(d)-listed waters.
Already contained in the Permit Compliance System (PCS). Practically obsolete upon submission.
(AL)

Eliminate required list of Concentrated Animal Feeding Operation (CAFO) facilities with permits.
Information is in PCS. (AL)

Region 7 requires Kansas to provide material needed to review all draft major and minor National
Pollutant Discharge Elimination System (NPDES) permits, including applications. Modify this
requirement to a select number of permits - maybe 10 per year - for quality control/oversight
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purposes. The current requirement far exceeds the requirements in the National Program Managers
guidance. (KS)
CWA regulations require submittal of all major NPDES permits to EPA. However, reporting on minor
NPDES permits is a Regional requirement.

During a meeting on Feb. 12, 2008, Region 7 discussed this subject with Kansas Department of
Health and Environment (KDHE). On March 13, 2008, Region 7 sent a letter to KDHE stating that
KDHE is no longer required to submit draft or final minor non-stormwater/non-CAFO permits to EPA.
Kansas and Region 7 have entered further discussion about minor NPDES permits during work plan
negotiations for the upcoming calendar year work plan. Region 7 and Kansas are also addressing
these concerns in an upcoming Memorandum of Agreement (MOA).

Region 4 has not yet been notified of Alabama's recommendations because the recommendations
were mistakenly assigned to the national Office of Enforcement and Compliance Assurance (OECA)
when in fact they are best addressed by Region 4. Alabama's request - and the resolution Kansas
and Region 7 achieved -will be transmitted to Region 4 in October2008.
W24: Harmonize Water Reports with Different Reporting Periods and
Frequencies

Priority Area: This recommendation falls under Priority Area 4. Click on the hyperlink to learn more about
this priority area.

Status:
. Implemented: Iowa
. Implemented In Part: Massachusetts, New Jersey

Trends:
. Eliminate redundant reporting
. Change reporting deadlines
States' Original Input
Reports that cover different reporting periods for no good reason. Some require Federal fiscal year,
some state fiscal year, and others are calendar year. (IA)

Nonpoint source program item #11 (WQ 16) - It is not clear if this information (number of waterbodies
identified by states as being primarily nonpoint source (NPS)-impaired that are partially or fully
restored) is expected to be provided by the states in a new report. Currently, this information is
provided within reports submitted to EPA. Information can be culled from those reports by EPA and
cross-referenced with the 2000 list. If an additional report is expected to be submitted by the states,
then this will result in duplicate data submission and is a reporting burden. (MA)

State must adhere to EPA reporting requirements in the Performance Partnership Agreement (PPA),
the Strategic Plan Subobjectives, the Program Activity Measures (PAMS), and in the state Nonpoint
Source (NPS) Annual Report. It would help if EPA would ask information once in one format, perhaps
annually or twice a year, but not in multiple formats with multiple deadlines. (NJ)
EPA Response
Reporting periods - Iowa recommended making reporting periods more uniform. During the FY08-
09 Performance Partnership Grant (PPG) work plan negotiations, Region 7 provided IA and all
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Region 7 states with a list of required reports for the water programs. Region 7 and IA discussed the
requirements for the reports (statutory, regulatory, regional, grants, etc.), and to the extent possible,
eliminated region-only reports or aligned the mandatory reporting requirements with the grant
reporting schedule. As a result, Iowa's PPG reports for all programs now have the same reporting
periods and reporting deadlines set to a semiannual schedule. IA agreed that this recommendation
has been fulfilled. Additionally, Iowa and Region 7 have agreed under the framework of Iowa's FY
08-09 PPG workplan the following:

In accordance with 40 CFR Part 35 regulations, IA Environmental Services Division
will provide progress reports on a semi-annual basis and a final grant report after the
conclusion of the grant period. The intent of the progress reports is to provide the
status of activities described in the grant work plan, measure progress and
performance, and highlight actual and anticipated changes which impacted or could
affect work plan performance. The final report provides an analysis of work plan
commitments versus work completed, analysis of the cumulative effectiveness of
work plans, discussion of potential or existing problem areas, and suggestions for
improvement.

The lA-Region 7 PPG workplan then outlines a detailed semiannual reporting schedule.

Duplicate reporting -
. Massachusetts' concern is related to the FY-07 National Water Program Guidance. WQ-16,
under the Strategic Plan subobjective, 2.2.1, "Protect and Improve Water Quality on a Watershed
Basis," was a Program Activity Measure (PAM) that was selected at the national level as a water
quality measurement tool. There is still national attention on the success of the NPS grant
reporting measure, both on the part of the Office of Management and Budget (OMB) in their
Program Assessment Rating Tool (PART) and at EPA's headquarters Office of Water (OW), who
released as both a FY-08 and FY-09 Program Activity Measure WQ-10 (formerly WQ-16),
"Number of water bodies identified by states as being primarily NPS-impaired that are partially or
fully restored" (see
http://www.epa.qov/cfo/npmquidance/owater/2008/final a measures appendix.pdf and
http://epa.qov/cfo/npmquidance/owater/2009/final ow 2009 quidance.pdf). Region 1 currently
requests annual reports from its states on the 319 program through their Performance
Partnership Agreement (PPA) annual report. However, Region 1 explained that at one point in
the past, EPA had asked for more frequent nonpoint source information updates as a source of
information update for Regional Progress video conferences with EPA management. Since that
time, frequency has been scaled back to annually.

. New Jersey expressed concern about multiple water program reports with various deadlines.
Region 2 worked with NJ to identify opportunities for streamlining Clean Water Act (CWA)
reporting requirements. Region 2 and New Jersey negotiated and finalized a new NJ PPA work
plan for State Fiscal Year (SFY) 2008-2010. As part of the PPA approval process, Region 2 will
meet again with NJ in the last quarter of calendar year 2008. Although the Region believes most
of the streamlining concerns have been addressed in the PPA, future discussions will allow
opportunity to discuss or clarify any remaining issues. Region 2 will continue to work with NJ to
identify opportunities to streamline reporting requirements.
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W25: Reduce Reporting Requirements on Concentrated Animal Feeding
Operations (CAFOs) Inspections
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Inpu.
State is required to inspect 50% of the National Pollutant Discharge Elimination System (NPDES)
Concentrated Animal Feeding Operations (CAFOs) on an annual basis. EPA should modify this
requirement to treat CAFOs like any other NPDES permittee. To increase the inspection/ reporting
burden for CAFOs to accommodate the new Federal CAFO regulations is not needed. The
requirement far exceeds reporting necessary to comply with the National Program Managers
measures. (KS)
W26: Provide Funds or Reduce Requirements for Class V Underground
Injection Control (UIC) Well Reports

Priority Area: This recommendation falls under Priority Area 12. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends: Additional resources needed for additional requirements
States' Original Inpu.
Collection of Class V inventory data either through processing of Underground Injection Control (UIC)
Inventory Information Forms or through targeted onsite inspections as is the case of high priority
Class V wells, is a time-consuming process requiring more than one FTE per state. Development of a
suitable database system within which this data can be stored and processed is also a costly and
time-consuming endeavor, one that must be contracted out. EPA must provide more funds to states
with only one FTE dedicated to the entire 1422 UIC Program (UT).
EPA Response
UIC primacy state-to-EPA reporting is currently being replaced by a national database which is
expected to reduce overall reporting burden. When UIC primacy programs begin using this national
database, they will no longer be required to file separate inventory, Program Activity Measure (PAM)
or OMB Form 7520 reports. Because the UIC program has not received an increase in funding in 19
years, EPA is not able to provide more funding to the states without its own increase in the funding.
More information about Class V wells can be found online.
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W27: Improve Data Sharing with Safe Drinking Water Information System
(SDWIS)

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Eliminate redundant reporting
. Streamline databases
States' Original Inpu*
Reporting of data should occur in one database, Safe Drinking Water Information System (SDWIS).
Additional databases such as Long-Term 2 (LT2)/Stage 2, Underground Injection Control (DIG), and
Source Water Protection data information are problematic and will lead to duplicative data. These
databases should be incorporated into SDWIS (MA).

Eliminate duplicative reporting: EPA asks states for additional manual reports, which contain data
already entered in SDWIS. (MD)

Either modify SDWIS Fed so that it extracts the necessary information from SDWIS State or send
ready-made queries to the state for data extraction related to incidental requests for information
related to non-state related incidents, e.g. lead and copper in Washington, DC schools (MT).

Information for drinking water enforcement (warning letters, NOVs, orders, penalties assessed and
collected) should be in SDWIS data system. Recommend eliminating this reporting requirement (SC).
EPA Response
Combining all drinking water databases into SDWIS - In the past, EPA has built separate data
systems to flow data to EPA from different programs, and has built a drinking water data warehouse,
in part, to integrate drinking water data wherever possible. The warehouse currently houses SDWIS-
Fed, National Contaminant Occurrence Database (NCOD) and Unregulated Contaminant Monitoring
rule (UCMR) data. A Long-Term 2 (LT2) module was built into SDWIS-State in November 2007. The
LT2 data will be integrated into SDWIS-State and will flow into SDWIS-Fed, and EPA will archive the
LT2 database in the warehouse after data are no longer reported into it, in 2012. EPA is also
planning to incorporate Source Water Protection (SWP) reporting into SDWIS in 2008.

The UIC database is separate because it is based on a different set of regulatory requirements. Data
collection for UIC would not fit into the relatively more complex SDWIS data model. See Priority Area
12 for more information on the UIC National Database.

Ready-made queries for incidental requests - Wherever possible, EPA builds queries that states
using SDWIS-State can use to meet EPA information requests. Some requests for information are
simply outside the scope of the Public Water System Supervision (PWSS) regulations or outside
SDWIS reporting capabilities. For example, EPA recently needed to track lead levels in DC schools
but since schools are not community water systems, SDWIS-Fed did not have information on them.
EPA infrequently requests information outside of SDWIS and does not consider these requests
particularly burdensome.

Duplicate and enforcement drinking water reporting - EPA routinely evaluates state programs by
conducting data verification audits, which evaluate state compliance decisions and reporting to
SDWIS-Fed. States manage their own processes and databases differently to document public water
system capabilities and their program management decisions concerning violations (or
noncompliance), and to record corrective actions undertaken. State data indicate that violations occur
infrequently at most public water systems (PWS). Violation data that states report to EPA (SDWIS-

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Fed) reflect only those major and minor noncompliance results that may lead to adverse public health
outcomes. Violations represent a small fraction of all the determinations states make which
demonstrates the safety of the nation's water supply. More information on data verification audits can
be found online.
W28: Eliminate Data Elements Required in Performance Partnership
Agreements (PPAs) that Are Already in Databases
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original In
Any and all data entered into Federal databases should be eliminated from the Performance
Partnership Agreements (PPAs) (e.g., National Pollutant Discharge Elimination System (NPDES)
program data in Permit Compliance System/Integrated Compliance Information System (PCS/ICIS).
EPA receives this data on an ongoing basis. Retrieval is at EPA's discretion. Eliminate requirements
for this same data in PPAs. (MT)
W29: Reduce Reporting Required for National Estuary Program (NEP) Grants

Priority Area: This recommendation falls under Priority Area 3. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Reduce reporting frequency
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States' Original Input
    The purpose of the 305(b)/303(d) report is to keep a current inventory of streams within each state
    that have been identified as "impaired." The report is required too frequently. It would make more
    sense to prepare the report every 5 years. (AR)

    Allow reporting every four years for303(d) and 305(b) reports. (CO)

    The Integrated Assessment (305(b) Report and 303(d) List) should be submitted every 5 years.
    Measurement any more frequently does not make sense because water quality does not change very
    quickly. Those states with unassessed waters could use randomized designs to monitor those waters,
    using a watershed approach, over a 5-year period. (DE)

    Hawaii would like to add its name to the twenty-one states asking to reduce the reporting frequency of
    the Integrated Report (five-year cycle). (HI)

    The biennial assessment of condition  of waters and listing of impaired waters is too frequent. Barring
    catastrophic events, water bodies do not change significantly over a two-year period. Change
    reporting frequency of five years. (IL)

    The Integrated Water Quality Monitoring and Assessment Report (303(d), 305(b), 314) should be
    modified and required less frequently. Much of the data is already provided in more detail in other
    documents (e.g., monitoring program  description is already provided in more detail in the state's
    Comprehensive Ambient Water Quality Monitoring and Assessment Strategy). Most of the interest in
    the Integrated Report relates only to the 303(d) listing portion, which can be provided conveniently
    through the Assessment Database (ADB). Eliminate all but this portion. (ME)

    Change 303(d) and 305(b) reports from 2-year cycle to 3- or 4-year cycle. (MD)

    The timelines identified in water quality measures are short timelines and does not reflect the
    timeframe required to see in-stream improvements.  Furthermore, these measures appear to assume
    that all waters are monitored every year.  In state, monitoring is completed on a 5 year rotating cycle
    and thus new data is not always available. State recommends that EPA provide language that
    annual/ multi-year reporting requirements do not apply to those states where a watershed cycle is
    used.  EPA should use the present integrated list and conduct comparative analysis on the data
    provided in the current list. (MA)

    Change the 2-year reporting cycle to a 5-year reporting cycle. (Ml)

    Two-year reporting frequency for both the list and report provides little/no environmental benefit. A
    four-year cycle would greatly reduce burden. (MN)

    Modify requirements to allow the 303(d) to mesh with the basin rotation plan. 20% of impaired waters
    would be reported per year with a complete, statewide list every 5 years. (MS)

    Offset the reporting period for economics by one or two cycles (2-4 years) from the current reporting
    cycle (e.g., for 2006 Integrated  Report, use years 2002-2004 as the period for economic benefit
    analysis). Furthermore, recognize that many restoration projects  take 10 or more years to achieve
    measurable benefits. (MT)

    A reporting frequency of 5 or 10 years would be more appropriate for the 305(b)/303(d) Integrated
    Report and would be more meaningful to the state and the public. (NV)

    Basic data for the Integrated Report is available in ADB (and this data is updated annually). Most
    importantly, the condition of many water bodies is assessed periodically (i.e., every 5 years) and
    barring catastrophic events, water bodies do not significantly change over a two-year period. State
    concurs with recommendation from ASIWPCA to institute a reporting frequency of five years, which
    coincides with both the NPDES/SPDES permit cycle and the state rotating basin monitoring scheme.
    (NY)

    Change reporting frequency from two  years to five years. Saves on limited state  resources. More in
    line with state's rotating basin approach  for monitoring. Water quality improvements are unlikely to
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occur in two years. Five-year frequency would allow state to devote more resources to making
information publicly accessible. (OH)

Biennial updates to the Integrated Reports are a burden. (OK)

The reporting burden for the Integrated Report is very large because it is required every two years.
The development of watershed projects to improved impaired water bodies, the implementation of
practices for water quality improvement, and the subsequent changes of water quality do not occur in
two years. Change reporting frequency to every four years. (SD)

Allow us to submit each year for those watersheds that have been completed or once per five years
to correspond with our watershed rotation schedule. (TN)

The Integrated Report cycle needs to be changed from a two-year cycle to a five-year cycle. To
ensure that the waters are being protected, the state could send an update of the ADB every year.
(UT)

EPA Assessment Group should work closely with its Standards Group to develop 303(d) listing
criteria that is not as burdensome. Right now, state is required to list a water body as impaired on a
single violation of a standard that is not based on a duration frequency. A single violation does not
necessarily mean impairment. (UT)

State recommends a five-year 305(b) reporting cycle. Modification/reduction/extension of reporting
requirements for the biennial portion of the reporting cycle would eliminate/reduce considerable
administrative work that appears to be of low value to Federal agencies. Much of what is stated in the
305(b) report is already available in other reporting documents. State has purposefully de-coupled the
biennial 303(d) list from the 305(b) report as the 303(d) list needs EPA approval and the 305(b) report
does not. (VT)

State recommends a five-year 303(d) reporting cycle. (VT)

Reduce the frequency of the 305(b)/303(d) Water Quality Assessment Reports to no more than every
four years. (VA)

The Water Quality Report to Congress frequency should be decreased to once every four years. An
interim report (short form) should be provided in the middle two years to report on progress which
would satisfy the statutory requirement. (Wl)
EPA Resoonse
Sections 305(b) and 314 of the Clean Water Act (CWA) require states, territories, and authorized
tribes to provide biennial reports to EPA on the condition of waters within their boundaries. EPA
regulations at 40 CFR 130.7 require states to provide biennial submissions of impaired waters lists.

EPA provides guidance on integrating these reports in a way that supports the agency's strategy for
achieving a broad-scale, national inventory of water quality conditions. The guidance is from EPA for
states, territories, authorized tribes, and interstate commissions ("jurisdictions") that help states
prepare and submit Section 305(b) reports to EPA. Use of the integrated report (IR) format provides
jurisdictions a recommended reporting format and suggested content to be used in developing a
single document that integrates the reporting requirements of Sections 303(d), 305(b), and 314. Use
of the IR format allows jurisdictions to report the water quality standards attainment status of all
waters, document the availability of data and information for each segment, identify certain trends in
the water quality conditions, and provide information to managers in setting priorities for future actions
to protect and restore the health of our nation's aquatic resources.

303(d) and 305(b) are a strong foundation of the Clean Water Act. The Integrated Report format is a
meaningful water quality tool and allows EPA to better understand the status of water quality.
Twenty-one states asked to reduce the reporting frequency of the Integrated Report. The majority
asked for either a four- or five-year frequency. EPA and the Association of State and Interstate Water
Pollution Control Administrators (ASIWPCA) formed a workgroup to handle this issue within the
existing regulatory framework, but have acknowledged that no single option will provide relief to all
states. Due to the necessity of statutory and regulatory changes required to alter the reporting
cycles, the states and EPA agreed to pursue a series of alternatives to respond to the underlying

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concerns of collecting and reporting the information on a biennial schedule.

EPA is working with ASIWPCA to develop the Integrated Report Guidance Memo for the 2010
reporting cycle. EPA expects to circulate a draft in fall 2008, and finalize the memo by the last
quarter of calendar year 2008. EPA agrees to move forward with the ASIWPCA group to see the
extent of burden reduction attained by the policy resolution. EPA will revisit the states' burden
reduction recommendations after the results of the 2010 Guidance Memo streamlining efforts can be
evaluated.
W31: Use Safe Drinking Water Information System (SDWIS) for All Water-
Related Reporting

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status: Will Not Be Implemented

Trends:
. Eliminate redundant reporting
. Streamline databases
States' Original In
Delete the significant noncompliance (SNC) report used specifically for capacity development as a
requirement - it is redundant (FL).

Submission of Public Water System Inventory data from Safe Drinking Water Information System
(SDWIS) State to EPA's ODS database system - the burden is currently placed on states to submit
all inventory data to EPA. The SDWIS State application is capable of tracking changes made to
required inventory data elements. It is our recommendation that only changes or modifications of
required data elements be submitted to EPA in data submissions (TN).
EPA Respon;
Delete the SNC report used for capacity development - The significant non-compliance (SNC)
calculations which form the basis for the capacity development report are currently being tested by a
joint EPA-state workgroup. As stated in Recommendation W3, the SNC desktop calculator is
currently in a pilot phase and will continue to be tested with an EPA-Association of State Drinking
Water Administrators (ASDWA) workgroup through FY-09. In the future, there may be an opportunity
to integrate the capacity development measure of historical SNCs with the SNC calculator being
developed for enforcement targeting. However, EPA will still require that states provide reasons for
systems in Historical Significant Non-Compliance (HSNC) or new systems in SNC.

Submission of PWS data from SDWIS State to EPA's ODS - EPA believes that for electronic data
exchange it is more efficient to update entire files than to isolate on data that has changed. For states
using SDWIS-State, the process for uploading data to the modernized SDWIS-Fed database, which
has been in place since 2006, has been completely automated.
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W32: Modify Reporting on the Public Water Supply (PWS) Supervisory Program

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status:
. FL: Implemented
. MA: Implemented

Trends:
. Eliminate redundant reporting
. Eliminate low-value data requirements
States' Original h
Delete the requirement for a plan for conducting all sanitary surveys for the fiscal year. Any
information EPA needs is in Safe Drinking Water Information System (SDWIS) (FL).

Sanitary survey data is a new requirement to be reported in SDWIS and Integrated Compliance
information System (ICIS), resulting in duplicate reporting. It is recommended that this data should be
reported in SDWIS only and that information be used to populate ICIS (MA).
EPA Resoonse
Region 4 does not request a plan for future sanitary surveys from Florida or any of its other states.
Region 4 requests only a list of what the state completed for the year as verification for what is
uploaded into SDWIS-Fed. Every state uploads their completed sanitary surveys into SDWIS-Fed on
a quarterly basis. Additionally, as part of EPA's Government Performance and Results Act (GPRA)
measures, the Region asks its states to submit an annual list of their completed sanitary surveys to
verify what is in SDWIS-Fed (because historically the two lists have been different at times due to
data lag). If Florida prefers that Region 4 use the data in SDWIS-Fed to calculate their compliance
with the sanitary survey GPRA goal rather than submitting an annual list, then Region 4 will do so.

EPA has elected to collect state sanitary survey data only in SDWIS. EPA's Office of Enforcement
and Compliance Assurance (OECA) confirmed that no state sanitary information is currently collected
in the Integrated Compliance Information System (ICIS), nor will it be in the future. Region 1 has
confirmed that they have not requested sanitary survey data in ICIS from Massachusetts. Please visit
the Web site for more information on these water data systems.
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W34: Use Safe Drinking Water Information System (SDWIS) for Operator
Certification Program Reporting

Priority Area: This recommendation falls under Priority Area 15. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends: Streamline databases
States' Original Input
Reporting of the operator certification program is currently required annually in a narrative report.
This function should be automated in an additional module in the Safe Drinking Water Information
System (SDWIS) (MA).
EPA Response
In collaboration with the Data Sharing Committee under the Association of State Drinking Water
Administrators (ASDWA), EPA will evaluate whether to include operator certification reporting in
SDWIS.
W35: Eliminate Requirement for Nonpoint Source Reduction Estimates Under
Clean Water Act (CWA) Section 319 Grants
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by ECOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
EPA requires nitrogen, phosphorus, and sediment reduction estimates and actual reduction
measurements under Section 319 grants. A modeling effort is needed up front for estimated
reduction, and a data collection effort is needed for actual reduction measurements. Modeling
estimated reductions is not useful and actual reductions cannot be well documented over the lifespan
of the grant. In most cases, the reductions will occur after the grant has expired. (MT)
W36: Reduce Frequency of Clean Water Act (CWA) Section 319 Reporting

Priority Area: This recommendation falls under Priority Area 10. Click on the hyperlink to learn more about
this priority area.

Status: Started But Not Finished

Trends:
. Reduce reporting frequency

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Eliminate redundant reporting
States' Original Input
State requests that the reporting schedule for the watershed 319 program be changed from quarterly
to annually. (IN)

Regions should eliminate additional reporting requirements for the 319 grant that are not required by
grant or nationally. Report annually rather than semi-annually. (MN)

Quarterly reports for the Non-Point Source Program should be reduced to annually. It would be more
efficient to incorporate this reporting as part of the Performance Partnership Agreement (PPA) annual
report. (Rl)
EPA Response
EPA's response to the states' recommendations is twofold. At the national level, EPA's Office of
Grants and Debarment (OGD) is responding by creating an Agency-wide grant reporting policy.
Among other things, this policy will reduce quarterly grant progress reports to a frequency of no
greater than semi-annually, except in instances of poor performers or where Regions and states have
otherwise agreed. In the case of Section 319, OGD expects that the policy will reduce reporting to an
annual frequency. Read more about the national grant reporting policy in the Priority Area 10
overview.

This national policy addresses Indiana and part of Rhode Island's recommendations. Furthermore,
Rhode Island may access information about including Section 319 grant funds in state performance
partnership grants.

Finally, in addition to national policies, Region 5 worked with Minnesota to address their
recommendation. (Region 5 will be happy to clarify or discuss any remaining issues with Minnesota,
if needed.) Specifically, Region 5 worked with Minnesota to refine Section 319(h)(10) reporting
requirements so that the state only provides the information already reported in the Grant Reporting
and Tracking System (CRTS).

But, CRTS only covers nonpoint source activities and projects supported with Section 319 funds.
Annual written reports from the states (that supplement and do not duplicate CRTS annual reporting)
are necessary to satisfy 319(h)(11) requirements relating to the overall progress states have achieved
in implementing their approved management programs. These reports are necessary in order to
work proactively with the states to reduce unliquidated balances in the Section 319 program.
W37: Reduce Frequency of Pre-Treatment Summary Report for State-Run
Programs
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
Reduce reporting frequency for Pre-Treatment Summary Report for State-Run Programs from semi-
annual to annual. It is not clear how semi-annual reporting adds value. (CT)
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W38: Eliminate Report on Environmental Benefits of Every State Revolving
Fund (SRF) Loan
This recommendation is not addressed in this progress report because the report focuses on the 16 priority
areas identified by EGOS in summer 2007 and this recommendation is not in a priority area. But, it is listed
here to ensure that a full list of all states' submissions is provided.
States' Original Input
EPA wants state to report on the environmental benefits of every State Revolving Fund (SRF) loan
including nonpoint loads by watershed. State has made literally hundreds of small nonpoint loans and
has not tracked what watershed each project is in. See no value in doing so. This requirement may
be more reasonable if state wasn't required to include nonpoint loans. (IA)
W39: Improve Data Sharing Related to the Operational Data System (ODS)

Electronic reporting data under 40 CFR 142.15(c) Special Reports should not be required. The
amount of decisions made that are to be reported to EPA does not necessitate a specific electronic
format. Paper reports of this information should suffice. (TN)
W40: Eliminate the Clean Watersheds Needs Survey

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