Lesson 3: Application Requirements

The application submitted to EPA is for approval of modifications or revisions to allow electronic reporting for one or more of the EPA-authorized programs implemented by your state. That is, you are seeking EPA approval to allow you to accept electronic documents in lieu of paperin lieu of paper When an electronic report takes the place of a paper report submitted to satisfy the requirements under another part of 40 CFR. In some states, the electronic reporting is done to make data collection and management easier, but the state requires that each report submitted electronically also be submitted as a signed paper copy. In this case, the electronic submission would not be in lieu of paper and CROMERR does not apply to the state. Some electronic reporting systems use a combined approach, where part or all of the data are submitted only electronically, but a wet ink signature on paper is also required. In these cases, the e-report (or at least the portions of it that are not also submitted on paper) is considered to be submitted "in lieu of paper" and CROMERR applies. In addition, there are special CROMERR rules under 40 CFR 3.2000(a) that govern the use of a wet ink signature on paper in conjunction with an e-report. (Additional detail on this combined approach is provided in Lesson 6.) for submissions made by facilities regulated under your states authorized programs.

For EPA to approve the program modifications, your state attorney general, or AG, must be able to certify that the state can continue to enforce these authorized programs based on electronic submissions. In addition, the system used to receive the electronic submissions must meet the standards spelled out in Section 3.2000 of CROMERR. These standards are discussed in detail in Lessons 5, 6, and 7 of this course.