CROMERR Program Announcements and Initiatives
On this page:
- Shared CROMERR Services and Regulatory Reform Agenda Open Call
- Streamlined Application Process for Compliance Monitoring Data Portal
- Updated CROMERR Application Cover Sheet Available
- Guidance and Template for Electronic Signature Agreement/Subscriber Agreement Now Available
- Many State Applicants Do Not Need to Submit a Legal Certification
- Special Application Process for E-Reporting by Local Government NPDES Pretreatment Programs
- Streamlined CROMERR Application Process for Solutions Using CDX Shared CROMERR Services
- Streamlined CROMERR Application Process for Off-the-Shelf Systems
- Hard-Copy CROMERR Applications No Longer Required
- New CROMERR Program Manager
EPA’s Office of Environmental Information held an open call on May 11, 2017 to update CROMERR stakeholders on Shared CROMERR Services available to them and CROMERR application process improvements that decrease implementation burden on co-regulators. The call also gave stakeholders an opportunity to provide feedback to EPA on the regulation. To view comments received by the agency, visit the “Evaluation of Existing Regulations” docket EPA-HQ-OA-2017-0190.
For additional information on EPA’s regulatory reform efforts, please visit EPA’s newly launched webpage.
CMDP relies on the EPA Central Data Exchange's (CDX) Shared CROMERR Services (SCS) for all CROMERR functionality, which is by definition CROMERR compliant. Applicants generally do not need to provide CROMERR technical documentation. Applicants do need to satisfy the legal certification requirements of CROMERR, and an initial CROMERR approval action is still required of EPA.
EPA revised the CROMERR cover sheet to better organize basic information about each application. Although the cover sheet format is not required, EPA needs the information to process CROMERR applications. It includes data fields for:
- Type of agency;
- Application point of contact
- List of components included in the CROMERR application;
- Brief system overview;
- List of programs covered by the application; and,
- List of attachments included with the application.
EPA now offers a guidance document for preparing an Electronic Subscriber Agreement/Subscriber Agreement. This resource provides an example of electronic signature agreement language that may be used, in part, to satisfy the electronic signature agreement or subscriber agreement requirement.
The CROMERR program recently completed a comprehensive analysis of approved Attorney General certifications on file, determining many of them to be broadly applicable for use by state-level agencies that may be preparing new CROMERR applications. States have two new options to streamline CROMERR application review and preparation time:
- Reference generic, approved CROMERR Attorney General (AG) certifications on file, or
- Supplement approved CROMERR AG certifications on file that are limited in state agency or program scope.
The AG certification is a key part of any CROMERR application; it demonstrates an authorized program’s ability to enforce electronically-collected regulatory information. Guidelines for CROMERR legal certifications are located on the CROMERR website.
See: Application tools and templates
See: CROMERR 101: Application requirements: Attorney General Certification
Check the table below for the status for each Attorney General certifications received from states:
|Approved, Generic Certification*||Approved, Limited Certification**||No Approved Certification|
|Alaska||Iowa **||New Hampshire (in process)|
|Colorado||North Carolina **|
* If you are a state-level agency planning new electronic reporting under your EPA-authorized regulatory program(s) and your state is listed as having a generic certification, you are still advised to inform your state Attorney General of your electronic reporting plans. EPA's assessment that an approved certification on file is broadly applicable is not meant to stand in place of a state Attorney General’s opinion but instead to simply give him or her the option to agree with EPA's assessment and forgo the need for further documentation and review. The CROMERR program can provide existing documentation if requested.
** These certifications are limited to use by a particular state agency or for particular state program(s) or both. EPA’s assessment determined that these state certifications could qualify as broadly applicable with the addition of a simple supplementary statement by the state Attorney General. If you are planning new electronic reporting under one of these states’ EPA-authorized programs, please contact the CROMERR program before preparing a new CROMERR Attorney General certification.
EPA developed a special review and approval process for POTWs pursuing electronic reporting under their authorized NPDES pretreatment program. CROMERR checklist templates are available for POTW applicants using commercially-developed solutions.
See: CROMERR Compliance for the Publicly Owned Treatment Works Pretreatment Program
POTWs implementing the full suite of Shared CROMERR Services and LinkExchange generally do not need to provide CROMERR technical documentation. These approaches are - by definition - CROMERR compliant unless special customizations are made to CROMERR-related functionality. POTWs likely still need to provide documentation to their pretreatment program approval authority related to electronic reporting requirements outlined by pretreatment program regulations.
Find your state or EPA Regional Permitting Authority contact. See:
Shared CROMERR Services (SCS) are API-based component solutions capable of providing for all CROMERR system requirements. An applicant using all SCS component solutions will typically have an e-reporting approach that is by definition CROMERR compliant. As such, applicants generally do not need to provide CROMERR technical documentation. Further, these applicants can mix and match options within the SCS components and take advantage of new SCS components as they become available without additional CROMERR review or approval.
Applicants do need to satisfy the legal certification requirements of CROMERR, and an initial CROMERR approval action is still required of EPA. Approval typically takes place during the system planning stages and, in cases where the legal certification requirement is already met, takes approximately 4 weeks.
SCS is an initiative of EPA's Central Data Exchange (CDX). The CROMERR program is not directly involved in the technical implementation of these component solutions.
To learn more about SCS, visit: Shared CROMERR Services and Components Integrated Project TeamExit
Agencies and companies interested in using these services should email the Shared CROMERR Services Help Desk (firstname.lastname@example.org) - which can provide a sandbox environment, assistant with integration, and provide information about setting up services with Lexis Nexis.
Streamlined CROMERR Application Processes for Off-the-Shelf Systems
For off-the-shelf solutions, EPA has simplified the CROMERR application process while maintaining compliance with the rule’s standards. These solutions typically offer significantly reduced paperwork requirements for applicants and expedited approval. For most applicants approval takes 4-8 weeks.
EPA National NetDMR
National NetDMR relies on the EPA Central Data Exchange's (CDX) Shared CROMERR Services (SCS) for all CROMERR functionality, which is by definition CROMERR compliant. Applicants generally do not need to provide CROMERR technical documentation. Applicants do need to satisfy the legal certification requirements of CROMERR, and an initial CROMERR approval action is still required of EPA.
“Tier 1” EPA CROMERR applications
EPA programs and regions with systems that that rely entirely or almost entirely on CDX CROMERR are typically, by definition, CROMERR compliant. Applicants generally do not need to provide CROMERR technical documentation. An approval action by the CROMERR program is not required, but can be provided as a courtesy. Unless there is a potentially unique use case requiring custom CROMERR functionality and/or an assessment related to CROMERR applicability, programs and regions will often only need to work with CDX on system set up.
See: CROMERR Overview for EPA Programs and Regions
EPA NPDES e-Reporting Tool (NeT)
NeT relies on the EPA Central Data Exchange's (CDX) Shared CROMERR Services (SCS) for all CROMERR functionality, which is by definition CROMERR compliant. Applicants generally do not need to provide CROMERR technical documentation. Applicants do need to satisfy the legal certification requirements of CROMERR, and an initial CROMERR approval action is still required of EPA.
Templates for some commercially-developed solutions
CROMERR checklist templates are available to authorized program applicants who choose to use a commercially-developed solution.
Hard-Copy CROMERR Applications No Longer Required
Applicants can now submit the majority of their application materials electronically. If attempting to send application files larger than 8 MB, please contact the CROMERR program to arrange for transfer.
The attorney general certification is the only application document that must be sent in hard copy. Send this document directly to the attention of; Shirley Miller at one of the addresses below.
New CROMERR manager
As of January 2019, Shirley Miller joined the CROMERR program as the new Program Manager. Shirley can be reached at (202) 566-2908 or Shirley Miller (email@example.com)