Proposed Charge for Matrix Priority Work Group
Issue List for Matrix Priority Work Group
August 4, 2006revised draft for Work Group Review
History of Document:First nine issues are taken verbatim from the Work Group Charge of July 10th, which was approved without any changes by the Work Group on July 12, 2006.
For each issue, status information has been added by EPA for Work Group discussion.
EPA has added one additional issue that has identified.
Document revised by EPA on August 4 per discussion at the August 2 Work Group Conference Callto add issues # 11, 12 and 13.
# / Issue / Status
What is an appropriate transition period for moving from WENDB[1] to RIDE? And how does this transition for required data elements, relate to the system transition from PCS to ICIS-NPDES? Are these two transitions essentially the same, or do they differ in certain ways? / States have indicated concern about the three year transition period in the 12/15/05 draft Policy Statement.
No recommendations or specific options have been developed here.
What criteria should be used to determine the transition period for moving from WENDB to RIDE for each State? Are there milestones/pre-conditions that must be addressed, e.g. system stability, upload tools, etc? When should the transition begin? For direct user states, when the Policy Statement is issued? For batch states, when the XML schemas are final? After a direct user state has had X months of using ICIS-NPDES? / There has been a general discussion of triggers for phasing the transition:
Technology based, such as Electronic DMRs.
Program/Rule based, such as the CAFO rule, Wet Weather SNC, Compliance Monitoring Strategy, and program (environmental prioritization).
Other triggers (that have not been discussed by the Work Group) might include: when an inspection occurs; when an enforcement action occurs;upon permit re-issuance, or upon permit application.
Assuming states will have different challenges in moving from WENDB to RIDE, do we need to provide states with flexibility during the transition period? How much variability is there in these challenges, and would categorizing states help us better understand and address these challenges? For example, states that have all of RIDE in an existing state electronic information management system may differ from states that manage some of the RIDE information in a paper manner.
[Note: the issue of some states not having particular RIDE information in any format, electronic or paper, is covered in #10 below] / The 12/15/2005 draft Policy Statement provided states with considerable flexibility during the three year transition period.
How should we proceed to reduce the existing state variability during the transition period while not exacerbating the problem? EPA has a need for usable, consistent, predictable data from across the states to provide national reports. The longer the transition period, the more critical this EPA need becomes. Would a phased approach with milestones provide sufficient predictability and certainty that national variability would be reduced during the transition period? / Work Group has not addressed this issue.
Universe Prioritization. Is there some priority subset of facilities that can be easily and consistently identified across the country that would be valuable to prioritize for coming into RIDE sooner? For the special program areas, can these be prioritized in a nationally consistent way for moving to RIDE? / EPA has presented background on existing rating system used to identify non-municipal majors.
EPA has presented concept of “priority minors” based on impaired water bodies or another NPDES program (environmental) based schema. EPA believes that any prioritization scheme should be practical to implement (based on readily available data) and could be based on multiple criteria.
State members of workgroup have understood need for this prioritization, but have expressed concerns about variability across states.
Data Family Prioritization. Are there prioritization options for data families? For example, do we prioritize requiring single event violation data for non-majors of a certain size or characteristic or sector? How does the wet weather SNC Policy (when finalized) factor into this prioritization? / Has not been discussed explicitly by Work Group. There is an understanding though that the data families are hierarchical in structure, and e.g., cannot enter DMR data until have facility and permit information in ICIS.
General Permit Covered Facilities. Do we need to clarify how ICIS and RIDE apply to General permit covered facilities? Is there a need to prioritize general permit covered facilities for coming into ICIS and RIDE in addition to the other prioritization schemes? / Work Group has not fully discussed this issue.
For Construction Storm Water Facilities Covered by General Permit, RIDE requires that all inspections and enforcement actions be entered into ICIS-NPDES. This then requires facility and permit level information be entered as well. EPA has indicated openness to considering whether there is an appropriate minimum size requirement that should be applied for such facilities?
Underlying Regulatory Triggers. Are there changes in particular NDPES program areas (e.g. CAFO) that need to occur before authorized states or regions will have certain RIDE data? / Work Group has only identified the CAFO rule, but has not gone into any specifics.
Electronic DMRs. Should entry of DMR data for non-majors that arecurrently not being entered be delayed until the authorized state or region has an operational electronic DMR tool for their facilities to use? / The matrices illustrate that E-DMR stems could be the trigger for non-priority minor DMRs.
Are there some RIDE that are not collected by states as part of their current NPDES programs and yet such states are adequately implementing the program? If yes, then could these data elements be dropped from RIDE? / Per discussion by the Resource Work Group as well as this Work Group, EPA developed a compliance monitoring RIDE data entry form to empirically test this question. ASIWPCA is planning to survey states to answer this question.
Will funding be tied to the dates in the transition period? / This has been a recurring issue in both the Resource Work Group and this one. EPA has provided states the opportunity to apply for National Environmental Information Exchange Network grants in FY04, FY05, FY06, and expects to also fund ICIS-NPDES and e-DMR data flow projects in FY07. EPA has also provided State and Tribal Assistance Grants to assist states with their transition to ICIS-NPDES since FY04.
Can a transition period be agreed upon before the XML schemas for ICIS-NPDESare final? / This has been a recurring issue in both the Resource Work Group and this one. Version 1.0 of the schemas were reviewed and approved by the TRG in July 2005 and posted to the Exchange Network. Version 1.4 of the schemas are anticipated to be ready for state and Network review in September 2006 and will then be finalized expeditiously.
How should differences between direct user and batch states be accounted for in the transition from PCS to ICIS-NPDES?
The activities that states must undertake during the transition from PCS to ICIS-NPDES will vary based on whether the state will be a “direct user” of ICIS, or a “batch user”.
For direct users, this transition time may include: (1) collecting any RIDE information that is not currently collected as part of current NPDES program implementation; and (2) entering data into ICIS-NPDES using the web screens.
For "batch" states, the transition time includes: (1) collecting RIDE data that is not currently collected as part of current NPDES program implementation; (2) entering the data into an applicable state system if not already done as part of program implementation necessary; (3) mapping to the ICIS-NPDES XML schemas, and then extracting the data; and (4) providing the data in the ICIS-NPDES XML schemas via the Exchange Network to EPA. Some batch states may need to make modifications to their state systems to facilitate steps 2 and 3.
States are expected to vary significantly on these steps. Further, some direct user states may also have particular batch data flows to ICIS-NPDES (such as DMRs); such direct users as sometimes called “hybrid states”. / The Work Group has had limited discussions on this issue, but no decisions or options have been proposed.
A related issue of when does the transition period start for direct users versus batch is already identified in issue #2 above.
1
[1] Everyone acknowledges there is some variability among states reporting of WENDB data elements today. While the vast majority of states are achieving the easy to measure goal of 95% completeness for major limits and DMRs, there are some data families in which many states are not providing certain data elements (such as Single Event Violations). There are some states that are going beyond WENDB, for example, by entering the limits and DMRs for many of their non-majors.