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Regulatory Alert - RA 02-2 - EXTENSION OF COMMENT PERIOD FOR EPA’s PROPOSED ELECTRONIC REPORTING AND RECORDKEEPING RULE AND ANNOUNCEMENT OF PUBLIC MEETINGS

Member Pipeline - Regulatory - Alert (RA 02-2)

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To: Members & Affiliates, and Legal Affairs Committees
From: National Office
Date: January 14, 2002
Subject: EXTENSION OF COMMENT PERIOD FOR EPA’s PROPOSED ELECTRONIC REPORTING AND RECORDKEEPING RULE AND ANNOUNCEMENT OF PUBLIC MEETINGS
Reference: RA 02-2

Action Please By:
February 18, 2002

On January 3, 2002, the U.S. Environmental Protection Agency (EPA) extended by thirty (30) days the comment period on its proposed rule establishing conditions for electronic reporting and the maintenance of electronic records. The comment period will now close on February 27, 2002. EPA originally proposed the Cross-Media Electronic Reporting and Records Rule (CROMERRR) on August 31, 2001 (66 Fed. Reg. 46162) (see Regulatory Alert 01-22) and extended the initial public comment period by sixty days on November 28, 2001 (66 Fed. Reg. 59392). As proposed, CROMERRR offers few, if any efficiency gains to members of the POTW community who may seek to transition from paper-based systems to electronic means of keeping records or submitting environmental reports. The new requirements may in fact drive regulated entities including POTWs away from electronic means of managing their regulatory compliance information and may require costly upgrades or improvements to existing electronic information systems to ensure conformity.

In addition to requesting input on how the proposed revisions might be improved, EPA is now seeking comment on whether the recordkeeping provisions of the proposal should be withdrawn and addressed in a separate rulemaking. AMSA believes this may be the best outcome.

EPA also announced the dates and locations for two public meetings on the proposed rule’s recordkeeping provisions. Designed to help foster continued review and evaluation of the proposal, the meetings will focus on electronic recordkeeping issues raised by the proposed rule, and will be structured to take comments on a series of questions EPA has identified including: What kinds of records are currently maintained electronically to satisfy EPA regulatory requirements? How will the proposed rule affect current electronic recordkeeping practices? The meetings will be held on:

A copy of the notice, which contains additional information on the location and scope of the public meetings, can be obtained at: http://www.epa.gov/fedrgstr/EPA-GENERAL/2002/January/Day-03/g109.htm.

AMSA continues to evaluate these requirements and encourages all agencies that generate or maintain information electronically to evaluate the impact of this proposal. If you are interested in providing comments to AMSA for incorporation into the Association's letter to EPA, please submit any feedback by February 18, 2002 to Chris Hornback, AMSA at chornback@amsa-cleanwater.org.