Like many states, Rhode Island found itself grappling with how to meet the requirements of EPA’s 2015 National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule. Under the rule, permittees must submit discharge monitoring reports (DMRs), notices of intent (NOIs), and program reports electronically rather than on paper.
The rule established two deadlines: the Phase 1 deadline, which required DMRs to be submitted electronically in 2016; and the Phase 2 deadline, which requires NOIs and program reports to be submitted electronically by December 21, 2020. The Rhode Island Department of Environmental Management (RIDEM) began using EPA’s Network Discharge Monitoring Report (NetDMR) service to satisfy Phase 1 DMR reporting requirements with great success. This track record, combined with the reality that RIDEM lacks the resources to implement a state-specific Phase 2 tool, led the agency to decide to employ EPA’s NPDES Electronic Reporting Tool (NeT) to meet the Phase 2 requirements for its Multi-Sector General Permit for Industrial Stormwater Discharges (MSGP). With the support of EPA, Rhode Island and EPA and its contractors worked cooperatively to incorporate Rhode Island’s MSGP requirements into the NeT tool.
The new tool went live in May and already is delivering the following benefits:
- Increased transparency. By using the E-Enterprise portal, the public can check on the status of a given facility by searching for permit type, issuer, and coverage status. In addition, the public can view actual permit documents, including Stormwater Management Plans, Rhode Island’s term for the Stormwater Pollution Prevention Plan, in other states.
- Increased data quality. NeT auto-populates NetDMR with the specific monitoring requirements for each permittee. This helps eliminate data entry errors and/or miscommunication errors.
- Increased compliance. Automatic reminder emails sent to permittees at the beginning of each monitoring period help them to meet their sampling and inspection requirements, with similar emails sent to remind permittees of their annual reporting requirements. Further, incomplete NOIs and annual reports cannot be submitted because the NeT tools reject documents with missing fields.
In an effort to proactively prevent non-compliance, instead of reactively responding to non-compliance, RIDEM and EPA continue to work to add automatic reminder emails to the NeT service that will send e-mails to permittees at the beginning of each monitoring period to help them to meet their sampling and inspection requirements, with similar emails sent to remind permittees of their annual reporting requirements.
With one permit now under its belt, Rhode Island plans to work with EPA to implement similar NeT services for its other general permits.
For more information, please contact Joseph Haberek of Rhode Island, and Joe Carioti and John Dombrowski of EPA.