The Proposed Rule does not change the amount of data that is currently required to be submitted under existing regulations. Currently, CAFOs covered by a general permit are currently required to submit NOIs once per five year NPDES permit cycle, and all permitted CAFOs are required to submit an annual report per 40 CFR 122.42(e)(4), which summarizes NPDES related information about their operations.
EPA accounted for the reporting burden for these reports when it promulgated the implementing regulations. The Proposed NPDES Electronic Reporting Rule does not add any additional reporting requirements for NPDES permitted CAFOs or any other NPDES regulated entity. The economic analysis for the proposed rule addressed the burden of changing the existing reporting from paper to electronic.
Additionally, EPA plans to "carry forward" data from one year to the next as part of its new electronic reporting tool. NPDES permitted CAFOs will benefit by only having to update the data that has changed in the new reporting year. This would reduce the data entry burden for the NPDES permitted CAFO. EPA has successfully used this approach in the Toxics Release Inventory-Made Easy (TRI-ME) electronic reporting tool software, which is used for EPA’s TRI program.