This comment letter from ACWA provides nineteen recommendations to EPA on ways they can improve the supplementally noticed proposed NPDES Electronic Reporting Rule. The association appreciates EPA’s goal to work with states to embrace new technology, improve public data accessibility and transparency, and to more effectively use limited collective resources. States believe that converting to electronic reporting can improve facility compliance and both directly and indirectly improve water quality. However, several states remain concerned that they are unprepared for implementation of a national NPDES eReporting Rule.
The rule was initially proposed on February 22, 2013, supplemental notice comments were due by Janaury 30, 2015.
ACWA Comment Letter NPDES eReporting Rule
