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  1. Home
  2. Cross-Media Electronic Reporting Rule

Application Tools and Templates

On this page:

  • Getting started
  • Application technical guidance
    • Checklist
    • Technical Solutions
    • Legal Certification
  • Application forms
    • Shared CROMERR Services Applications
    • EPA-developed off-the-shelf solutions
    • Commercially-developed off-the-shelf solutions
    • Custom-built systems
  • Maintaining compliance
  • Information for Publicly Owned Treatment Works (POTW)
  • Information for EPA Headquarters and Regional Programs

The tools and templates on this page are designed to help determine CROMERR applicability and assist application preparation for state, tribal and local governments authorized to administer EPA programs. POTWs follow a special process jointly implemented by EPA Office Environmental Information (OEI), Office of Water (OW), and the states (for the purposes of CROMERR) Includes the District of Columbia and the United States Territories, as specified in the applicable statutes.. EPA headquarters and regional programs also follow a special process. Please use the links above to skip to special sections describing these processes.


Getting started

The CROMERR Program can help you navigate the approval process and provide you with helpful resources and expertise. Get started with these resources:

Does CROMERR Apply to your e-Reporting System? (pdf) (1.19 MB, 5/20/22)

CROMERR Step-by-Step Guide on How to Create and Submit a Successful Application (pdf) (5.16 MB)


Application technical guidance

Many state applicants do not need to submit a legal certification

Many states already have approved, broadly applicable CROMERR Attorney General certifications.

See: Status of Attorney General certifications received from states

The following documents are useful for applicants preparing a CROMERR "system checklist". Only substantially or entirely custom-developed systems require comprehensive CROMERR technical documentation. The system checklist is the recommended format for this technical documentation. A blank system checklist can be found under the Application Forms section below; several pre-populated system checklist templates are available for off-the-shelf solutions requiring limited CROMERR technical documentation.

Plan to implement an off-the-shelf solution or the Central Data Exchange (CDX) Shared CROMERR Services? You will still need CROMERR approval, but you may not need to provide CROMERR technical documentation.

Checklist

  • CROMERR Application Reviewer Guide (docx) (May 2017) This guide evolved from EPA's own internal procedures for reviewing CROMERR applications. It provides detailed technical specifications around each of the CROMERR requirements.
  • Sample Applications and Checklists Learn how previous applicants have met CROMERR requirements for their electronic reporting.

Technical Solutions

  • CROMERR Application Challenges and Solutions (pdf) (363.68 KB)
    Common application challenges, examples of effective approaches to resolving them, and example EPA-approved systems that have used these approaches.
  • User Identification, Verification, and Authentication: Challenge Question Second-Factor Approach (pdf) (111.02 KB)
  • CROMERR Electronic Signature Agreement Guide (pdf) (220.49 KB, July 2017)  Example electronic signature agreement As defined in § 3.3 of CROMERR, an agreement signed by an individual with respect to an electronic signature device that the individual will use to create his or her electronic signatures requiring such individual to protect the electronic signature device from compromise; to promptly report to the agency or agencies relying on the electronic signatures created any evidence discovered that the device has been compromised; and to be held as legally bound, obligated, or responsible by the electronic signatures created as by a handwritten signature. language that may be used, in part, to satisfy the electronic signature agreement or subscriber agreement As defined in § 3.3 of CROMERR, an electronic signature agreement signed by an individual with a handwritten signature. This agreement must be stored until five years after the associated electronic signature device has been deactivated. requirement of CROMERR.

Legal Certification

  • CROMERR Legal Certification Guide for State Attorney General or Local Government or Tribe Certifying Official Statement (pdf) (2.81 MB, 12/8/22)
    This document provides guidance, templates and examples that will help when preparing official statements from an attorney general or a certifying official from a local government or tribe.
  • Crosswalk between CROMERR rule requirements and system checklist (xls) (73.5 KB)
    This crosswalk identifies how the CROMERR system checklist relates to requirements outlined in the CROMERR rule. It is intended as a quick reference for understanding where the system checklist sections stem from in the rule.

Application forms

To apply for CROMERR approval, start by completing the Application Cover Sheet.

  • CROMERR Application Cover Sheet (pdf) (566.92 KB)

NOTE: Customized application cover sheets exists for several off-the-shelf solutions. Applicants pursuing these solutions an complete the cover sheet above but will likely find it easier to complete the cover sheet specifically tailored for the system they are implementing.

The table below can help CROMERR applicants determine what information is needed in their application.

Application Element EDOTS CDX (CDX Integrated)* EPA-Vetted COTS EDOTS (Not Integrated by a CDX representative)* & Hybrids Custom

Cover Sheet

General CROMERR Cover Sheet, Cover Sheet for EDOTS, EPA-Vetted COTS or Cover Sheet for POTWs.
Legal Required of co-regulators only: Attorney General or legal representative Certification or leveraging letter.
Checklist - System Functions Section CROMERR checklist not needed May use appropriate pre-approved vendor-specific CROMERR checklist template with any modifications shown in bold and/or italics. May use appropriate CDX or pre-approved vendor-specific CROMERR template checklist, with any modifications shown in bold and/or italics and provide additional information for CROMERR system functions not included in vendor or CDX services. May complete a standard CROMERR Checklist in its entirety.
Checklist -Business Process Section CROMERR Checklist not needed
  • May use pre-approved vendor-specific CROMERR checklist template with any modifications shown in bold and/or italics and provide additional information for CROMERR business processes not included in vendor services, or
  • May complete a standard CROMERR checklist in its entirety
  • May use appropriate CDX or pre-approved vendor-specific CROMERR template checklist, with any modifications shown in bold and/or italics and provide additional information for CROMERR business processes not included in vendor or CDX services, or
  • May complete a standard CROMERR checklist in its entirety,
May complete a standard CROMERR Checklist in its entirety.
Other Template Electronic Signature Agreement (with any customizations shown in bold and/or italics) or Custom Electronic Signature Agreement. Example Copy of Record as produced by the system.

Next, locate your system/approach in the following list and, if applicable, complete any additional form(s) and/or template(s) specific to that system/approach. Applicants pursuing off-the-shelf approaches not yet evaluated by the CROMERR program or custom-developed solutions will find relevant forms under the link for custom-built systems.

Shared CROMERR Services Applications

The EPA Central Data Exchange As defined in § 3.3 of CROMERR, EPA's centralized electronic document receiving system, or its successors, including associated instructions for submitting electronic documents. (CDX As defined in § 3.3 of CROMERR, EPA's centralized electronic document receiving system, or its successors, including associated instructions for submitting electronic documents.) Shared CROMERR Services (SCS) are application programming interface (API) component solutions which can meet individual CROMERR system requirements or provide an end-to-end CROMERR compliant solution. SCS reduces cost and technical barriers to CROMERR-compliant electronic reporting. Applicants implementing the full suite of SCS generally do not need to provide CROMERR technical documentation.

The CROMERR program is not directly involved in the technical implementation of these services. To learn more, visit the EPA Exchange Network's CDX Shared CROMERR Services Integrated Project Team site.

Agencies and companies interested in using these services should contact the Shared CROMERR Services Help Desk -- which can provide a sandbox environment, assistant with integration, and provide information about setting up services with Lexis Nexis.

EPA-developed off-the-shelf solutions

EPA National NetDMR

Uses: Stormwater and pretreatment Discharge Monitoring Reports under National Pollutant Discharge Elimination System (NPDES)
See: EPA National NETDMR Support Portal

EPA National NetDMR CROMERR Application Cover Sheet (pdf) (91.68 KB, 5/20/22)

* EPA-authorized programs applying to use National NetDMR are not required to complete a CROMERR system checklist. Please refer to the system-specific cover sheet for application documentation that may be required.


EPA NPDES e-Reporting Tool

Uses: Supplements NetDMR for additional NPDES reporting
See: Final National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule

EPA NPDES Electronic Reporting Tool (NeT) CROMERR Application Cover Sheet (pdf) (303.41 KB)

* EPA-authorized programs applying to use NeT are not required to complete a CROMERR system checklist. Please refer to the system-specific cover sheet for application documentation that may be required.


EPA Compliance Monitoring Data Portal

Uses: Reporting of drinking water lab sample data

EPA Compliance Monitoring Data Portal CROMERR Application Cover Sheet (pdf) (160.06 KB, 5/20/22)

* EPA-authorized programs applying to use CMDP are not required to complete a CROMERR system checklist. Please refer to the system-specific cover sheet for application documentation that may be required.


EPA Combined Air Emissions Reporting System

Uses: Clean Air Act reporting under 40 CFR parts 50-52

EPA Combined Air Emissions Reporting System Cover Sheet (pdf) (755.33 KB)

EPA Combined Air Emissions Reporting System Checklist Template (docx) (45.39 KB, 11/16/22)

EPA Combined Air Emissions Reporting System Rules of Behavior (docx) (49.58 KB, 11/16/22)

* EPA-authorized programs applying for CAERS can use the template checklist linked above. SLT Reviewers will ultimately have to electronically sign the Rules of Behavior in CDX.

Commercially-developed off-the-shelf solutions

Some vendors of Commercially-Developed Off-The-Shelf Solutions (COTS) might have templates that can be used for the CROMERR checklist for state, local, or tribal (SLTs) agencies using their vendor products. CROMERR applicants using vendor products may want to reach out to the vendor to see if that vendor has a template they can use. Please note, CROMERR is a rule and not a software certification program. So, authorized-programs pursuing these solutions must still submit CROMERR applications requesting EPA to take action under 40 CFR part 3 when using a vendor template.

In the past, EPA provided vendor templates on this website. However, EPA is no longer providing templates for COTS because some templates were not regularly being updated by vendors to reflect revisions to their CROMMER solutions. This resulted in the templates not accurately reflecting the most up-to-date business processes and system functions. To obtain the most recent version, please contact the vendor of your COTS system.

Custom-built systems

Applicants not using an off-the-shelf solution or component-based solutions such as Shared CROMERR Services usually have custom-built systems.

To minimize rework, such applicants are encouraged to work with the CROMERR program during the design phase and to submit system documentation for draft review.

Blank CROMERR System Checklist (doc) (117 KB, 2/24/21)

* Typically, applicants with custom-built systems are required to provide additional documentation beyond the CROMERR checklist that describes their system’s conformance with the CROMERR standards.

For more information about documenting signature approaches on CROMERR applications, review the diagram for additional detail, or review the text only version of the Completing the CROMERR Checklist diagram.

Diagram for completing the CROMERR checklist by signature approach for priority and non-priority reports.

Maintaining compliance

Applicants are responsible for informing the CROMERR program about changes that may affect their CROMERR compliance.

Examples of significant changes could include changes to the types of file formats that affect how the copy of record As defined in § 3.3 of CROMERR, a true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all the information provided in the electronic document with descriptions or labeling of the information. A copy of record includes: 1) All electronic signatures contained in or logically associated with that document; 2) The date and time of receipt; and 3) Any other information used to record the meaning of the document or the circumstances of its receipt. (COR As defined in § 3.3 of CROMERR, a true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all the information provided in the electronic document with descriptions or labeling of the information. A copy of record includes: 1) All electronic signatures contained in or logically associated with that document; 2) The date and time of receipt; and 3) Any other information used to record the meaning of the document or the circumstances of its receipt.) is maintained, as well as changes to the technologies that may be used for file transfer or for creating electronic signatures on transmitted reports.

For information, see:  Notification and Approval of Changes to Approved CROMERR Applications: For States, Tribes, and Local Governments (pdf) (157.43 KB, May 2020)  and FAQs: Modifications to Approved Applications


Information for Publicly Owned Treatment Works (POTW)

EPA’s Office of Water (OW) and Office of Environmental Information developed a hybrid approach for processing requests to modify approved POTW NPDES pretreatment programs to allow for electronic reporting.

For more information, see: 

2024 CROMERR for POTW Pretreatment Program Guide (pdf) (331.8 KB)

Local governments interested in reporting NPDES pretreatment data electronically should contact the CROMERR program (cromerr@epa.gov) or EPA’s OW Pretreatment Team (EPA_HQ_Pretreatment@epa.gov).


Information for EPA Programs

EPA has designated the Central Data Exchange (CDX) as the Agency's mechanism for providing CROMERR-compliant electronic reporting services for all EPA data collections. All systems that are subject to CROMERR must use CDX's CROMERR services to ensure that their data collections or exchanges have met Agency enforceability requirements.

For more information, reference the Enterprise Architecture Policy’s Data Exchange Procedure (CIO 2122-P-04.0) on EPA's intranet.

Only those EPA programs requesting special customizations to CDX's CROMERR services engage with the CROMERR program in technical documentation and review.  Almost all other EPA programs implementing CDX's CROMERR services are CROMERR-compliant by definition and approved automatically. 

Completing the CROMERR Checklist:

  • Does the system receive submissions that require signature?
    • If no, applicants must complete the following sections of the CROMERR checklist: 8-11 and 18-20.
    • If yes, Does the system use e-signature?
      • If no, applicants must complete the following sections of the CROMERR checklist: 8-11 and 18-20.
  • Does the system use e-signature?
    • If yes, Does the system collect priority reports As defined in § 3.3 of CROMERR, the reports listed in Appendix 1 to part 3.?
    • If no, applicants must complete all sections of the CROMERR checklist except 1a and 1b.
  • Does the system collect priority reports?
    • If yes, Applicants must complete all sections of the CROMERR checklist, including 1a and 1b.

*Examples of common electronic signature approaches include use of a secure ID/government-issued identifier, use of a PIN/Password combination, and a PKI Enables users of a basically unsecure public network, such as the Internet, to securely and privately exchange data and money through the use of a public and a private cryptographic key pair that is obtained and shared through a trusted authority. The public key infrastructure provides for a digital certificate that can identify an individual or an organization and directory services that can store and, when necessary, revoke the certificates.. Some applicants choose a wet-ink-on-paper signature that is mailed after reports are submitted electronically. While this is an acceptable signature approach, it is not an electronic signature per the definition in CROMERR section 3.3.

This diagram is provided for guidance purposes only.

Cross-Media Electronic Reporting Rule

  • Learn about the Cross-Media Electronic Reporting Rule (CROMERR)
  • CROMERR 101 Training
    • Lesson 1: Overview of the Final Rule
      • Lesson 1: What Does the Rule Do?
      • Lesson 1: What Does the Rule NOT Do?
      • Lesson 1: Who is Affected?
      • Lesson 1: When Does the Rule NOT Apply?
      • Lesson 1: End of Lesson
    • Lesson 2: Quick Tour of the Final Rule
      • Lesson 2: End of Lesson
    • Lesson 3: Application Requirements
      • Lesson 3: Required Elements of a CROMERR Application
      • Lesson 3: Typical Application Components
      • Lesson 3: Cover Sheet
      • Lesson 3: Attorney General (AG) Certification
      • Lesson 3: System Description(s)
      • Lesson 3: Submitting the Application
      • Lesson 3: End of Lesson
    • Lesson 4: The EPA Review and Approval Process under Part 3
      • Lesson 4: Technical Review Committee (TRC)
      • Lesson 4: End of Lesson
    • Lesson 5: CROMERR-Compliant Electronic Reporting
      • Lesson 5: Overview of CROMERR Requirements for Electronic Reporting
      • Lesson 5: Requirements for Authorized Program e-Reporting
      • Lesson 5: Standards for an Acceptable Electronic Document Receiving System
      • Lesson 5: Defining "Valid Electronic Signatures"
      • Lesson 5: System Requirements for Receiving e-Signatures
      • Lesson 5: Priority vs. Non-Priority Reports
      • Lesson 5: Title: Enforceability Provisions
      • Lesson 5: Title: End of Lesson
    • Lesson 6: Using the Checklist to Work through System Requirements
      • Lesson 6: Registration
      • Lesson 6: Signature Process
      • Lesson 6: Submission Process
      • Lesson 6: Signature Validation
      • Lesson 6: Copy of Record (COR)
      • Lesson 6: The CROMERR Requirements and the Checklist Items
      • Lesson 6: End of Lesson
    • Lesson 7: From Requirements to Solutions
      • Lesson 7: From Requirements to Specific Solutions
      • Lesson 7: From Requirements to Specific Solutions Two Key Decisions
      • Lesson 7: Key Decision 1 - Type of Credential Used
      • Lesson 7: Key Decision 1 - Type of Credential Used (continued)
      • Lesson 7: Key Decision 2 - Defining the Copy of Record (COR)
      • Lesson 7: From Key Decisions to CROMERR-Compliant Solutions
      • Lesson 7: End of Lesson
    • Lesson 8: Four Critical Checklist Items
      • Lesson 8: CROMERR System Checklist Items
      • Lesson 8: Additional Sample Solutions
      • Lesson 8: End of Lesson
  • Overview for CROMERR
  • Program Announcements & Initiatives
  • Approved CROMERR Applications
  • CROMERR Federal Register Notices
  • Application Tools & Templates
  • Sample Applications & Checklists
  • Glossary
  • Frequently Asked Questions
  • Help Desk
Contact Us about Cross-Media Electronic Reporting Rule
Contact Us to ask a question, provide feedback, or report a problem.
Last updated on March 20, 2025
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