CROMERR Program Announcements and Initiatives
On this page:
- 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 local government NPDES pretreatment e-reporting
- Streamlined CROMERR application review for component solutions
- Streamlined CROMERR application review for off the shelf systems
- Hard-copy CROMERR applications no longer required
Updated CROMERR application cover sheet available
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.
See: CROMERR Application Cover Sheet
Guidance and template for Electronic Signature Agreement/Subscriber Agreement now available
EPA developed a guidance document for developing a 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.
See: CROMERR Electronic Signature Agreement
Many state applicants do not need to submit a legal certification
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 |
|---|---|---|
| Alabama | California ** | Missouri |
| Alaska | Iowa ** | Nebraska |
| Arizona | Kentucky** | New Hampshire |
| Arkansas | New Jersey | |
| Colorado | North Carolina ** | |
| Connecticut | Oklahoma ** | |
| Delaware | Tennessee ** | |
| Florida | Virginia | |
| Georgia | ||
| Hawaii | ||
| Idaho | ||
| Illinois | ||
| Indiana | ||
| Kansas | ||
| Louisiana | ||
| Maine | ||
| Maryland | ||
| Massachusetts | ||
| Michigan | ||
| Minnesota | ||
| Mississippi | ||
| Montana | ||
| Nevada | ||
| New Mexico | ||
| New York | ||
| North Dakota | ||
| Ohio | ||
| Oregon | ||
| Pennsylvania | ||
| Rhode Island | ||
| South Carolina | ||
| South Dakota | ||
| Texas | ||
| Utah | ||
| Vermont | ||
| Washington | ||
| West Virginia | ||
| Wisconsin | ||
| Wyoming |
* 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.
** 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.
Special Application Process for Local Government NPDES Pretreatment e-Reporting
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
Email: CROMERR Program (cromerr@epa.gov) or EPA’s Office of Water Pretreatment Team (CromerrPOTWrequest@epa.gov)
Streamlined CROMERR application review for component solutions
Shared CROMERR Services (SCS) are component solutions designed to address the most challenging CROMERR system requirements. An applicant using all SCS component solutions will have an e-reporting approach that provides all required CROMERR system functionality.
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 (sharedcromerrservices@epacdx.net)
Streamlined CROMERR application review for off-the-shelf systems
For off-the-shelf solutions, EPA aims to simplify the CROMERR application process while maintaining compliance with the rule’s standards. These solutions may offer significantly reduced paperwork requirements for applicants and expedited approval.
EPA National NetDMR
Since 2013, applicants using the National NetDMR checklist template undergo a simplified review and approval process.
See: Application tools and templates
“Tier 1” EPA CROMERR applications
Since 2014, EPA programs and regions with systems that that rely entirely or almost entirely on CDX CROMERR services undergo an expedited approval process that does not require a CROMERR checklist.
See: CROMERR Overview for EPA Programs and Regions
EPA NPDES e-Reporting Tool (NeT)
Since 2015, applicants for NeT submit a CROMERR cover sheet developed specifically for the tool; some applicants may need to submit a legal certification and subscriber agreement, if customized. A CROMERR checklist is not required, and the application undergoes a simplified review and approval process.
See: Final National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule
Templates for some commercially-developed solutions
CROMERR checklist templates are available to authorized program applicants who choose to use a commercially-developed solution.
See: Application tools and templates
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.
Email your materials to: the CROMERR Program (cromerr@epa.gov) and Karen Seeh (seeh.karen@epa.gov)
The attorney general certification is the only application document that must be sent in hard copy. Send this document directly to the attention of Karen Seeh at one of the addresses below.
- U.S. Postal Service deliveries: 1200 Pennsylvania Avenue, NW, Mail Code 2823T, Washington, DC 20460
- Hand deliveries: 1301 Constitution Avenue, NW, EPA West, Room 6408J, Washington, DC 20004; Phone: (202) 566-1175