We guide you through Pennsylvania’s electronic DMR reporting requirements in an easy to understand way.
If you’re covered under the PAG-03 stormwater permit in Pennsylvania, or any of their other various stormwater permits, chances are you’ve heard about the new electronic DMR reporting. Pennsylvania’s eDMR reporting may seem like a sudden shift, but the reality is all states are now conducting electronic DMR reporting.
However, there’s a pretty good chance you aren’t entirely sure what’s involved. A completely new process like electronic DMR reporting in Pennsylvania is going to need some time and explanation to get the process down pat. So, let’s dive into the PA eDMR reporting requirements, how they work, and help you figure out what you need to know.
PA eDMR Reporting Advice - RMA vs PADEP
First off, you might be wondering why you’re taking advice from us and not the PADEP.
Let’s make this clear. We’re not in the government, we’re consultants. We make our money working for folks like you, not with environmental groups or regulatory agencies. Our clients are located all over the U.S., and we’ve dealt with NPDES stormwater permits in around 30 states at this point. We know the ins and outs and our way around stormwater permits and the reporting requirements. Meaning, this isn’t official advice from a regulator or a government agency.
What this is, however, is solid advice and guidance from consultants who specialize in helping people minimize the amount of time, headache, hassle, and money they need to deal with their stormwater permit. We wade through the BS and get down to what’s required, saving you time and energy. So now that you know who we are and why we’re talking about this, let’s really dive into it.
Just an FYI: At the time of writing this article all the links we’ve provided below to help you out are live with the PADEP's current eDMR documents. If they change, you may need to use a different document than we’ve linked to below!
Pennsylvania’s eDMR Reporting Requirements
Like I said, Pennsylvania is now requiring that all permittees throughout the state comply with the national electronic reporting rule adopted by the EPA. That’s right, the head honcho’s in Washington came up with this rule, not the states. This is a federal thing so it’s not going to go away.
In an age where more and more people are ‘going green’, electronic DMR reporting is something I can get behind. It saves you time, money, and it cuts down on paper & mail being delivered which should make everybody feel good. Honestly, did you like dealing with the post office anyway?
This new requirement might seem daunting, but it's something simple and easy to comply with. Most companies in the State of Pennsylvania that are covered by one of the many NPDES permits the state has to offer have most likely received a letter regarding this matter by now. If not, it’s probably slow in the mail and still on its way. The letter is nothing to worry about, just an overview of what you need to do to meet this requirement.
Who needs to use PA’s eDMR reporting?
This new electronic DMR reporting requirement in Pennsylvania applies to pretty much every permittee in the Keystone State. This applies to Water Quality Management Permits to NPDES Individual Permits to the new PAG-03 General Permit, and basically everything in between.
If your permit requires you to conduct analytical monitoring of stormwater discharges from your facility, this applies directly to you.
Why do I have to do eDMR reporting in Pennsylvania?
You know how little kids like to ask why a lot? What’s the most common answer from parents?
Because I said so.
That’s no different here. The state made changes in their rules so they can comply with USEPA regulations.
Why do you have to do electronic DMR reporting in Pennsylvania? Because the PADEP said so.
It’s the new regulation, and you must comply with it. The old days of pen & paper and mailing your DMRs in is dead and gone. It’s time to “go green” and go digital.
What do I have to do to comply with Pennsylvania’s new eDMR reporting requirement?
Complying with this new requirement is simple, and is broken down for those with general stormwater permits in Pennsylvania, and those with individual permits.
eDMR Reporting for General Stormwater Permit Holders in Pennsylvania
Here’s what you must do to comply with the new regulations:
- Complete and submit a registration form to become an eDMR participant. This is a three-page form that contains questions you should be able to answer in your sleep. Some questions pertain to permittee and facility information and user account information (which you should get from your Greenport account, which I’ll explain in a moment). This form should be simple to complete and comes with attached instructions in case you have any questions or concerns. This form can be found here.
- Complete and submit an eDMR Trading Partner Agreement Form. This form is even easier than the first. It’s a simple one-page form that asks for a signature and that’s it. It basically states that you read and understand all the rules regarding electronic reporting; that you are a responsible official, that false reporting is a no-no, that electronic signatures have the same legal effect as written signatures, and a few other little bits of information. This form can be found here.
- You must submit the first page of your permit. This is the page that contains all the permittee information. It has the permit number, the facility name, the issuance/expiration dates of the permit, and other things of that nature. This way, when you submit these forms, the DEP will have all the information needed to correctly put you into the system.
- You must submit all the effluent limitation tables from within your permit. This one might be a little tricky but shouldn’t be too difficult. Effluent limitation tables will have the information you compare your stormwater analysis results to. This will help the DEP set up your eDMRs.
- Submit all blank copies of any DMRs you use. These can be found in your permit or can be found here. You need to make sure you submit the correct one! The DMRs go by Appendices, which are outlined from within the permit. A DMR for Appendix A might be used by one type of industry, and a DMR for Appendix B might be used for an entirely different industry, so it’s important to know which one applies to you.
And that’s it! You do that and you’re up and running.
eDMR Reporting for Individual Stormwater Permit Holders in Pennsylvania
For permittees covered by individual permits, you only must do numbers 1 and 2 above. That’s it!
eDMR Reporting & Greenpoint Account Information
In addition to submitting the necessary documents, you must also create an account on the PADEP’s Greenport online system. The website you’ll need can be found here. And instructions can be found here.
One thing I would like to point out is this: when you file for an account, it is crucial that you give yourself the role and access as a certifier. They can view and obtain the reports, view submittal status, enter data, attach forms, and submit DMRs. This role is the ONLY one that gives you the ability to submit the DMRs, so it’s very important that you give yourself this title.
Most other aspects of setting the system up should be basic and self-explanatory. All in all, this is a simple account to set up.
Our recommendation is that you do this prior to filling out and submitting all those forms, as you need information from your online account to do so.
When do I need to have electronic DMR reporting setup by?
To comply with this requirement, you must create an account on Greenport and submit all the necessary documents by December 21st 2016.
That’s about 2 months to do this! It takes anywhere from one to two months for the DEP to set you up in the system after they receive your paperwork, so the sooner you do this the better.
As I’ve outlined above, getting into compliance doesn’t take an arm and a leg, it’s submitting a few documents and creating an online account, something that should take you all told more than an hour to complete. Why wait?
What if I miss the eDMR reporting setup deadline?
Don’t. Get it done ahead of time and save yourself the agony of having to deal with regulators giving you guff. Failing to get yourself setup in time might end up with the DEP taking enforcement actions against you.
Do you want to roll the dice on this one? Just get it done. It’s quick and easy and not worth any sort of enforcement action at all.
What comes next with Pennsylvania’s eDMR reporting?
Now that you’ve submitted all the required documents and you’ve created an account online, you might be thinking, now what?
All we can tell you is sit tight.
With the recent issuance of the new PAG-03 stormwater permit and the requirement for electronic reporting, this is new to all of us.
Our advice is to follow the rules of your permit and submit your DMRs when they are due, as early as possible. With the PAG-03 permit, this will be done on a semiannual basis. Make it a habit to get these reports submitted on time.
All reports you’ll submit will most likely be available to you at the beginning of the monitoring / inspection period, just in case you want to get things done early. I’m saying that because that’s what we've been told by folks in the PADEP. What you'll need to submit is going to be based on your permit, your industry, and other factors, so learn your permit inside and out.
Since this is a new system for lots and lots of us I can only assume there's going to be a learning curve to electronic DMR reporting in Pennsylvania. Our clients all over the country are getting themselves ready for electronic reporting, and we’re sensing a lot of folks are expecting some bumps and bruises along the way initially.
Our best advice right now is to give it your best shot the first time you need to submit. Try to get it done completely, correctly, and on time.For additional help on eDMR reporting in Pennsylvania, click here to contact us or give us a shout at 609-693-8301.