On Tuesday, the U.S. Environmental Protection Agency (EPA) extended the comment period for its proposed NPDES Electronic Reporting Rule by 45 days to Thursday, December 12. The proposed NPDES Electronic Reporting Rule is pretty straightforward. Currently, EPA allows paper/hard copies to be submitted for application and renewal of National Pollutant Discharge Elimination System (NPDES) permits, as many ready mixed concrete producers currently are required to obtain. EPA is proposing to switch entirely to an electronic format. Prior to EPA’s comment period extension notice, NRMCA submitted comments on the proposed rule.

While NRMCA is not opposing the proposed rule, NRMCA commented that EPA has underestimated the time necessary to appropriately implement the changes. Specifically, NRMCA commented, "for industry and states to be able to meet the above requirements, more time is needed than proposed. Due to the foreseeable planning, initial investments, training, personnel hiring and necessary troubleshooting, in addition to, EPA, states, tribes and territories developing new electronic reporting tools, NRMCA recommends changing the implementation dates as follows: Phase 1: Three years after effective date of the final rule; Phase 2: Four years after effective date of the final rule. If we have learned anything from the Affordable Care Act (ACA), it is that new computer based programs, software and hardware will inevitably have 'glitches' that will need time to be worked out. Also, NRMCA estimates the cost to the ready mixed concrete industry to be about $500 per plant for training alone. There will certainly be other hardware and software costs which are unable to predict at this time."

Click here for more information on the proposed. For more information, contact NRMCA's Gary Mullings at gmullings@nrmca.org or Kevin Walgenbach at kwalgenbach@nrmca.org.