U.S. Environmental Protection Agency 1

How to Create and Submit a Successful

CROMERR Application

Step-by-Step Guide

July 2015
U.S. Environmental Protection Agency 2

•What is CROMERR?

•Purpose of CROMERR

•CROMERR Requirements

INTRODUCTION

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The Cross-Media Electronic Reporting Regulation 

(CROMERR) program at the Environmental 

Protection Agency (EPA) provides the legal 

framework for electronic reporting from regulated

entities to the EPA and to states, tribes, and local

governments that are authorized to administer EPA 

programs.

What is CROMERR?

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CROMERR seeks to maintain the level of corporate and individual 

responsibility and accountability during the transition from a paperbased to an electronic reporting environment.

Key benefits of CROMERR program:

• Ensures that the electronic reports are as enforceable as their paper 

counterparts by providing standards for

– Electronic Signatures

– Integrity of copy of record

• Provides a central point for EPA to receive and act on applications in

lieu of going through individual EPA offices and regions

Purpose of CROMERR

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Under§3.1000(b)(1), to obtain EPA approval of program revisions or 

modifications to incorporate electronic reporting, a state, tribe, or local 

government must submit an application to the EPA that includes four elements:

1. Attorney General (AG)/Legal Certification. Verifies that the state has sufficient 

legal authority to enforce the program using electronic reports, as described in

§3.2000(c).

2. System Descriptions. Systems used to receive e-reports must meet the CROMERR

standards listed in§3.2000(b), and provide for e-signatures (or follow-on paper 

signatures) that meet the requirements of§3.2000(a).

3. System Upgrades. System changesthat may affect CROMERR compliance.

4. Other Information. Additional information that should be considered by EPA 

during evaluation of the application.

CROMERR Requirements

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•Getting Started

•Traditional Application

•Maximizing Successful Submissions

•Application Submission

CROMERR APPLICATION

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• Begin by accessing the 20-item CROMERR System Checklist that

lays out application requirements; this document is called the Blank 

System Checklist and can be found on the CROMERR website*

• Access and populate either the two generic application cover

sheets or a customized cover sheet available for certain systems; all 

available cover sheets can be found on the CROMERR website

• Contact cromerr@epa.gov to determine if an AG/Legal 

Certification is required for your application

• If your not using an off-the-shelf (OTS) approach, we strongly 

encourage you to engage EPA in the system design phase and 

submit a draft checklist for initial review

* Note: Many OTS systems have template system checklists. If available, these

should be used by the applicant. Some OTS systems do not require system 

checklists. See the CROMERR website for more information. 

Getting Started

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Templates for CROMERR Cover Sheets are on the CROMERR website

Note: Some systems have customized cover sheets. If the application is for multiple systems, Page 2 

should be completed for each system. 

Traditional Application: Cover Sheet

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Two-Page Cover Sheet
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• §3.1000(b)(1)(i) requires a letter demonstrating sufficient legal authority

to enforce the application’s authorized programs using electronic reports.

• For states, the AG (or designee) must sign the certification letter.

• For tribes and local governments, the Chief Administrative Official or Officer

(CAO) (or designee) must sign the certification letter.

• A guidance document including a template for preparing your AG/Legal 

Certification is available on the CROMERR website. 

Note: Some states have approved generic AG Certifications on file. Contact 

cromerr@epa.gov to determine if an AG Certification is required for your application

Note: Letters signed by a designee must explicitly state that this individual has delegated

authority from the AG or CAO to sign the certification letter.

Traditional Application:

Attorney General/Legal Certification

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The descriptions that an applicant provides for each of the 20 checklist 

requirements reflect how the applicant's approach will meet the 

CROMERR §3.2000(a) and (b) requirements through a combination of 

business processes and system functionality

When applicable, supporting documentation should be attached to the 

descriptions. Attachments may include the following:

• Electronic Signature Agreement

• System user guides

• Process diagrams

• System screenshots and/or printouts

Note: Before submitting your application, ensure that the checklist items that are relevant to 

your system are complete. Please use template system checklists if available. 

Traditional Application: System Checklist

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An official application submission will trigger the formal review process by the 

CROMERR Technical Review Committee (TRC).

Unless using a checklist template for an OTS system, we strongly encourage you

to submit a draft version for initial review BEFORE submitting an official

application. This draft submission enables you to:

• Avoid restarting the entire application process to make minor edits

(resubmission will delay your application by at least 30 days)

• Obtain technical assistance and clarification on any aspect of the application

• Receive timely feedback regarding any changes required to maximize the

chance of the application’s approval

• Expedite the formal application review process

Please direct all questions regarding draft submissions to the CROMERR program 

at cromerr@epa.gov.

Maximizing Successful Submissions

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For UPS, FedEx, or courier mail deliveries:

U.S. Environmental Protection Agency

Office of Environmental Information

Attn: Karen Seeh

1301 Constitution Avenue, N.W.

EPA West, Room 6408J

Washington, DC 20004

Phone: (202) 566-1175

For U.S. Postal Service deliveries:

U.S. Environmental Protection Agency

Office of Environmental Information

Attn: Karen Seeh

1200 Pennsylvania Avenue, N.W.

Mail Code: 2823T

Washington, DC 20460

Electronic submissions are encouraged!

• Applications can be submitted via e-mail to Karen Seeh at seeh.karen@epa.gov,

along with a courtesy copy to cromerr@epa.gov

• AG/Legal Certifications must be submitted in hard-copy; please send to the 

following address:

Application Submission

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•Traditional Review Process

•System Approach and CROMERR Approval Timeframes

•Comparison of Two Approaches

•Approved Application Modifications 

APPLICATION REVIEW PROCESS

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• EPA's Completeness Review (§3.1000(b)(3)(i))

– EPA first reviews applications to ensure that enough information has been 

provided for a CROMERR compliance evaluation

– This may be an iterative process with the applicant

• EPA's Approval Review (§3.1000(c))

– Upon determination of completeness, EPA reviews applications to assess the 

approaches outlined for compliance with CROMERR requirements

– This may be an iterative process with the applicant

• Administrative Approval Steps

– The CROMERR TRC’s approval recommendations are voted on by the committee and 

confirmed by EPA executives

– Approved applicants receive a letter signed by EPA

– Applications are officially approved upon publication of a Federal Register notice

Note: Some of these steps are combined or eliminated for some OTS systems

Traditional Review Process

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System approach is a key factor in the resources and time required to achieve

CROMERR approval. Generally, applicants can expect the following approval

timeframes, depending upon their system approach:

• Longest time: All or mostly all custom development – Minimum 1 year

• Short time: Custom development that leverages several Shared CROMERR

Services components for CROMERR functionality – 6-9 months

• Shortest time: Off-the-shelf (OTS) solutions that provide for all or almost all 

CROMERR functionality and business processes – 2-4 months

System Approach 

and CROMERR Approval Timeframes

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Opportunities exist for applicants to develop CROMERR-compliant solutions quickly and 

cost-effectively plus reduce CROMERR compliance maintenance costs

• Off-the-shelf (OTS) products offer solutions for a range of electronic reporting needs

• CROMERR component services are available from EPA’s Central Data Exchange for 

implementation with any system

Significant reductions in application burden and approval timeframes have been

achieved via “streamlined” CROMERR review and approval processes being developed

for these new approaches

• These streamlined processes are further aided by ongoing CROMERR process

improvements such as application templates, online forms, and process

standardization/automation

Note: Information about Shared CROMERR Services and OTS Solutions are available on the CROMERR 

website

System Approach 

and CROMERR Approval Timeframes (cont.)

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Rhode Island NetDMR (Streamlined Using Automated Template)

• Completeness review: 33 days

• Committee vote: 17 days

• Agency executive concurrence: 7 days

• FR Notice publication: 15 days

Illinois eDMR (Traditional Approach)

• Completeness review: 149 days

• Committee vote: 38 days

• Agency executive concurrence: 7 days

• FR Notice publication: 30 days

Note: Custom-built systems often undergo a lengthy, iterative review process which significantly affects the 

approval timeframe

Comparison of Two Approaches

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295 days

101 days

Application 

Received

FR Notice 

Published

Application 

Received

FR Notice 

Published
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• Per §3.1000(a)(4), approved applicants must notify EPA of any changes

that may affect compliance with CROMERR, including changes to:

o System functionality

o Policies and business processes

o Laws

• Process:

o Outline any changes in an email to cromerr@epa.gov

o EPA may request additional information and/or may need to address 

issues with the applicant to maintain compliance

o A formally amended application may or may not be required

o EPA acts to approve the changes formally or informally

• Applicants with approved OTS or component-based systems are not

required to inform EPA of mass system updates implemented by 

vendors

Approved Application Modifications

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• EPA CROMERR Website

• CROMERR Application Tools & Templates

• CROMERR 101 Training

• CROMERR Help Desk

– Application status

– Regulatory/policy questions

– Technical assistance

– Other inquiries

Application Resources

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