           Improvements for the Cross-Media Electronic Reporting Rule
                          (EPA/OEI/OIC/IESD, 5/9/13)

EPA's Office of Environmental Information is actively working with its state co-regulators to assist them in meeting the requirements of the Cross-Media Electronic Reporting Rule (CROMERR).  OEI is committed to provide tools, services and a streamlined review and approval process.    

EPA is confident the recent improvements identified below will improve states' ability to meet the CROMERR requirements and EPA's review and approval process.  These improvements will allow EPA to be prepared to support the implementation of the proposed NPDES e-reporting rule for CROMERR requirements.


   1. Automating EPA Internal Review Processes
      
      EPA developed an automated workflow system to expedite the CROMERR application review process for all new EPA and co-regulator e-reporting data systems that are required to meet the CROMERR performance standards (e.g., electronic signature, non-repudiation).  The CROMERR Program and Stakeholder Management System was deployed in the fall, 2012. (Priority Goal Milestone for 2013)
      
      With this core system in place, EPA is implementing other tools to speed up application processing.  

   2. Providing Technology Support Services 
      
      EPA built a generic suite of reusable services offered through the Central Data Exchange (CDX) that EPA and its co-regulators (states, tribes, and territories) can use as they develop e-reporting systems to meet EPA's CROMERR performance standards (e.g., electronic signature, non-repudiation) for reporting under Title 40 of the CFR.  These services will promote efficiency in the use of federal, tribal, and state funds by providing CROMERR services in a centralized way.  Rather than creating or maintaining their own, each program may elect to use the generic services. (Priority Goal Milestone for 2013)
         
      The Shared CROMERR Services Integrated Project Team (IPT), made up of state and EPA representatives, was established in the fall of 2012 under the auspices of the Exchange Network Leadership Council.  The IPT conducted a review and assessment of needs in order to reduce costs to co-regulators and support compliance with CROMERR requirements.  The IPT recommended making the CROMERR services reusable and managed in a centralized way so that state and tribes can leverage them for their own reporting programs in a more efficient and cost-effective manner.  The following technology support options are currently available:
      
         * User Registration
   *             Identity Proofing
   *             Electronic Signature
   *             Copy of Record.
         
      EPA developed specifications and documentation for states, tribes, and territories to adopt and implement the generic suite of reusable services offered through CDX that meet CROMERR performance standards.  This will also enable third party software developers to offer solutions to the regulated community if desired.  Further, it would enable states and tribes without existing electronic reporting programs to more easily develop completely electronic reporting processes and may provide efficiency to others that currently have a system in place and choose to use these services as well.  (Priority Goal Milestone for 2013)
      
      
      
      

   3. Extending Outreach among Co-Regulators 

      EPA is aggressively reaching out to states and tribes to support them in the CROMERR application approval process and continues to provide assistance in addressing outstanding issues.  EPA will continue to improve its communications with the CROMERR community through various efforts, such as: 
      	
   *             EPA is actively engaging state applicants on all phases of their application:  completeness review, approval review, and Agency approval;
   *             EPA will provide expanded access to approved solutions, updates and status on CROMERR applications;
   *             EPA will enhance available CROMERR application guidance materials, technical assistance, and develop additional materials as needed;  
   *             EPA will establish a CROMERR central customer help desk; and 
   *             The IPT will conduct ad hoc state forums to highlight and identify approaches that facilitate CROMERR compliance.

