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CROMERR Submission Information and Guidelines for State Partners

The Cross-Media Electronic Reporting Regulation (CROMERR) provides the legal framework for electronic reporting (ER) under all of EPA's environmental regulations. States must receive CROMERR approval before using NetDMR (note that EPA Regions have already been approved). The first step in the CROMERR approval process is to prepare and submit the application package. The application package must contain:

  1. An Attorney General Certification Statement (provided below) with copies of the relevant statutes and/or regulations.
  2. A listing of the electronic document receiving systems that do, or will receive, electronic submissions addressed by the program revisions or modifications being requested, together with a description of each system that specifies in detail how it will satisfy the requirements of CROMERR. The application should indicate, for each system, which electronic submissions the system will be used to receive, and for each such submission, whether the submission involves electronic signatures.
  3. For each system, a schedule of upgrades that may affect future CROMERR compliance (to the extent that such upgrades can be anticipated).
  4. Any other information necessary to demonstrate compliance with CROMERR.

It is recommended that all states use the basic NetDMR checklist provided below, which was approved earlier for the NetDMR software as it will be implemented by EPA Regional offices. In an effort to expedite the Technical Review Committee (TRC) review process of your application package, please note any state changes to the NetDMR checklist in redline. You will also need to make minor updates in some areas to replace "region" with "state", update dates, etc. If the checklist is not revised in regard to substance, please note on the top of the checklist: SUBSTANCE OF DOCUMENT IS NOT MODIFIED FROM EPA-PROVIDED EXAMPLE. In addition, you should not be required to modify the two image files (JPEG) below that show process flow diagrams for the NetDMR signature process and NetDMR registration process. Lastly, please complete the two cover sheet templates provided on the CROMERR Web site. If these measures are taken, the TRC review and approval of your CROMERR application should be expedited.

Additional information on the CROMERR approval process can be found at http://www.epa.gov/cromerr/tools.html. This Web site provides a step-by-step guide on the CROMERR process, in addition to Frequently Asked Questions for States, Tribes and Local Governments (8pp, 187K, PDF) and several other documents. Please be advised that there has been one change to the step-by-step guide that should be noted: submittals should be sent to Andrew Battin, Acting Director of Office of Information Collection (OIC) rather than Mark Luttner.

If you have questions about the Attorney General Certification (provided below) that will be needed in regard to state enforcement authority on electronically-signed documents, contact Michael Le Desma (ledesma.michael@epa.gov) via e-mail or phone at (303) 462-9453.

CROMERR System Checklist and Materials for Application Package

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