Introduction to National Collaboration on Electronic Reporting for Issue Voting
From EITLC Wiki
Issue Overview
Use of electronic reporting is growing, piecemeal, across the United States. Given this rate of change in related sectors, there is a growing public expectation for National comprehensive electronic reporting. Development of a national strategy, or rough consensus, around one optional collection process which identifies the roles and flow areas for data exchange in pursuant of a regulatory requirement, would lead to development of extensible applications, the ability to share enterprises, better access to the primary data sources, utilization of data access and exchange, potential increased quality assurance potential prior to submission, and burden reduction/savings across environmental programs. Within national collaboration around electronic reporting lies one of the few areas where the environmental information community can be directly responsive to the economic downturn, as facilities and agencies would no longer need to conduct data entry. The desired result is streamlined, effective electronic reporting. Opportunity Space Recognizing the similarities (often driven by common Federal requirements) of these reports and the demonstrated ability of the Environmental Information Exchange Network to enable many different approaches to electronic reporting (e.g. common xml forms, CDX hosted applications used by states, etc.), this area represents a tremendous opportunity to accelerate and reduce State implementation costs of adoption of electronic reporting. For the most part, States and EPA have converged onto two models for facilities to submit data: Web form entry and semi-automated or manual file upload. Distribution of special purpose desktop software for use by reporters is in general declining. Using the two remaining methods, facilities are often required to report similar datasets through different forms to both States and EPA. However, if the format of data reported is standardized through shared EPA/State business rules, it would enable a Facility to EPA to State data flow rather than Facility to EPA AND Facility to State. Additionally, if partners utilize electronic reporting of data rather than manual upload, this allows for ease of sharing that electronic data with other partners or agencies. If EPA provides the software option on the Web, facilities and states no longer need to download it. Software could be used rather than shared.
For the purposes of planning joint work, the overall “world” of electronic reporting can be described in the following components:
- Shared data formats/templates. Ex: eDMR, eDWR, and WQX
- Jointly developed, shared software that is implemented locally by multiple partners. Ex: NetDMR
- Electronic reporting as a CDX service; to gain efficiencies, CDX provides receiving services on behalf of States. Ex: TRI program
- Electronic reporting Support Web Services: coordination powered by Web services between EPA and States to make electronic reporting work better and work better together. These might include cross-certification for security, pre-population of forms, or providing underlying data needed by States. Ex: NetDMR application which pulls from ICIS.
- Shared Requirements, Practices, and Procedures: Sharing of best practices in the implementation of electronic reporting systems. Ex: pin/password management, archiving approaches.
In many cases a single ER project could contribute to, or be supported by all of these components.
In exploring this issue, the critical need is development of business rules/service agreements between EPA and States and standardization of format. States and EPA would need to sign an MOU (memorandum of understanding) in which EPA agrees to run the software and States agree to use it.
Potential Focus Areas for Priority Action Team
- TRI: TRI offers an excellent example of the opportunities available around electronic reporting. With facilities required to report the same data to both EPA and States, an identical form for reporting was developed to streamline the process. OEI and partners already involved in national collaboration around electronic reporting of TRI would be available to brief the EITLC on next steps for increased utilization of the flow.
- GHG: A rule exists for Greenhouse Gas, which will soon be implemented. Using the two remaining methods for submitting data, facilities are often required to report similar datasets through different forms to both States and EPA. However, if the format of data reported is standardized through shared EPA/State business rules, it would enable a Facility to EPA to State data flow rather than Facility to EPA AND Facility to State. By creating an identical form as was used for TRI, GHG would reduce the reporting burden on facilities. There is already much focus and energy around GHG reporting, so less of a need for EITLC attention. A word of caution, however, is that GHG data collection is somewhat connected to annual air emission inventory collections so these should be considered together.
- eManifest: A major opportunity space exists around development and use of eManifest, as the current practice is run on paper and therefore offers muddled tracking data. An eManifest rule will be developed in the near future, which should consider a similar design to TRI and GHG. This flow will include elements of both facility-EPA-State as well as facility-EPA/facility-State. In order to streamline such an extensive collection, there must be a strong EPA/State partnership.
- Operational issues related to the implementation of CROMMER
Potential Next Steps
- Run a comprehensive analysis of opportunity areas – particularly TRI and eManifest
- Develop common service agreements for use by EPA and State agencies
- EPA Receipt as Shared Service: Explore options for a volunteer reporting process in which facilities report to EPA which then shares data with states. Ex: TRI data flow
- Engage States either considering or not currently utilizing electronic reporting
