Cross-Media Electronic Reporting Rule

CROMERR Program Announcements and Initiatives

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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

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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

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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:

  1. Reference generic, approved CROMERR Attorney General (AG) certifications on file, or
  2. 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:

Status of Attorney General certifications received by states as of December 2016
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  
New Mexico    
New York    
North Dakota    
Rhode Island    
South Carolina    
South Dakota    
West Virginia    

* 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.

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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 ( or EPA’s Office of Water Pretreatment Team (

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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 (

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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

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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 ( and Karen Seeh (

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

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