Are you required to use NetDMR to submit your reports?
DMR Yes (with very few usually short term exceptions), if your permit requires you to submit DMR reports, then you are required to use NetDMR to do so.
What is NetDMR and what do you need to know about it before you set up an account?
The EPA calls NetDMR a Program Service. The NetDMR is housed within a system called the Central Data Exchange network (CDX). CDX is what is sounds like a superhighway for submitting data to the EPA. When you set up an account, you are setting up a CDX account and the NetDMR Program Service at the same time. Because they are like a hand in a glove, I think of them as the combination CDX-NetDMR. Each person who intends to work with DMRs in CDX-NetDMR must do so through their own account. Your CDX account belongs to you. It does not belong to your employer. You cannot inherit anyone’s account and you cannot give your account away to anyone. You only need one CDX account for all of your EPA related reporting and you can use the same CDX account for your entire career by just changing the organization and email address associated with your account. If or when you no longer need your account, do not abandon it until after you have deleted all of the roles that you have for all permits and locked your account.
The EPA has built a streamlined process for creating an account and adding the NetDMR program service to it in the same process. There are two sets of instructions. One for those who need an account that has an electronic signature associated with it and the other for those who do not.
If you already have a CDX account, simply log in to it and add the NetDMR Program Service for Colorado to it.
If you set up an account that has an electronic signature associated with it, that e-signature is based on your personal identity. It is not connected with your job, or who you work for, and it does not give you any authority to use it to sign documents. It is simply just your electronic signature.
How to set up a NEW CDX-NetDMR account
- Instructions, an account that has an electronic signature (to sign DMRs with)
- Instructions, an account for those who don’t sign DMRs (permittees, labs, regulatory authority)
Essential NetDMR sites.
- Get help from the EPA: Click Here
- Streamlined CDX-NetDMR account creation page.
- The main CDX log in page.
If you fail the Lexis-Nexis identity verification process
If you fail the online identity verification process, your e-signature will not be activated. If your e-signature is not active, the system will not be able to automatically use your signature to electronically sign and officially file your Electronic Signature Agreement (ESA) in CDX for you. Until your ESA is signed and officially on file, you will not be allowed to enter NetDMR through your “Permittee (signature)” role. To solve this problem you must print a copy of your ESA. You must write your full legal name in the field near the top of page one then sign and date it in ink below the numbered paragraphs. Finally, you must deliver your ink signed agreement to the address below. Once we determine that your ESA has your valid signature on it we will activate the electronic signature associated with your “Permittee (signature)” Program Service role and you will be allowed to enter NetDMR.
Records Center
Water Quality Division
Colorado Department of Public Health & Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Who is authorized to sign the DMRs of Colorado-issued permits
…and how do you get that authority if you don’t already have it? Colorado requires all those who intend to sign DMRs for a Colorado-issued permit to establish their authority to sign them through their permit before they go into NetDMR and request the ability to sign them through their NetDMR account. Please notice that this is a sequential process that only works well when the steps are taken in this order. If you reverse the order it will always end up taking longer to get approved than it would have if you had not done so.
Those who have the authority to sign DMRs are described on their permit as either the person who is either legally responsible for that permit, or as the duly authorized permit compliance representative of that responsible person. Unfortunately we use two different terms to refer to the person who is legally responsible for a permit. We either call them the Permittee, or the Responsible Official (RO). We usually refer to the duly authorized permit compliance representative of the RO as the DMR Cognizant Official.
If your job description says that you are responsible for signing DMRs, but the permit does not describe you as the DMR Cognizant Official, then the RO will have to submit a Change of Contacts form or process to update their permit. If you are the replacement for the person who is described on the permit as the Responsible Official, then the process that you must go through to assume responsibility for the permit will depend on whether your permit must be managed through the Colorado Environmental Online Services (CEOS) system, or if it must still be still be managed using paper forms. If your permit still requires paper forms, the Change of Contacts form is used for both claiming responsibility for a permit as that permit’s Permittee/RO as well as for designating a new DMR Cognizant Official.
The State of Colorado is in the process of transitioning from a paper forms based permitting process to an entirely online permitting process. At this time, most of the NPDES Clean Water permits that are effective in Colorado can only be applied for, updated, managed, modified, transferred, & terminated, through the CEOS account of the RO for that permit. Please bear in mind that you may have applied for your permit using paper forms but that permit and other similar permits may have been converted to permits that must be managed through CEOS.
If you are uncertain about whether your permit must be managed through CEOS or not, call the Permits help line and ask. Before you call, please prepare for the first question that they will ask …what is the permit/certificate ID of your permit?
Permits help
- Phone: 303-692-3517
- Email: cdphe_wqcd_permits@state.co.us
If you need to be able to manage (modify, terminate, etc.) a permit that can only be managed through a CEOS account, and only by that permit’s RO, and you either did not apply for that permit yourself through your own CEOS account, or that permit was pulled into CEOS after issuance; then you will have to go through a process to gain control over that permit in CEOS.
The first step in this process is for you to set up your own RO account in CEOS. Next, log in to your CEOS account, search for the permitted facility by name (use keywords only), and associate your account with that facility. Next, claim responsibility for the permit(s) that are associated with that facility. Then, finally choose the option to “replace the current RO” for each of the permits that you claimed. At this point, if you are doing this to gain control over a permit that was originally applied for (by you or someone else) using paper forms and subsequently pulled into CEOS after the permit became effective then you will be asked to enter an email address that you must get from someone at the Permits help desk. On the other hand, if you are doing this to assume responsibility for a permit that someone else applied for through CEOS, the email address that you need to enter is that of the previous RO.
General info on how Permit/DMR roles are managed in NetDMR
Administrators control access to permits in NetDMR. NetDMR itself does not restrict which permits you can request access to or which roles you can request for those permits. Regardless of which role you request or which permit you request that role for, an Administrator must decide whether to approve your role request.
Who is the Administrator for the DMR Signatory role?
State Regulatory Authority Officials who are also NetDMR Instance Administrators, are responsible for determining who is allowed to sign DMRs in NetDMR. The only factor that they consider when deciding whether to approve a DMR Signatory role request or not, is whether the person who submitted the request is officially described on the permit that they are requesting that role for as someone who has the authority to sign its DMRs. If they have that authority when they submit their Signatory role request it will be approved.
Within 2 business days of when you submit your DMR Signatory role request, we intend to either approve it or send you an email message telling you why it couldn’t be approved with instructions on what you must do to fix the problem.
If you submit a Signatory role request that is not approved within 2 business days and if you are not sent an email message explaining why, you should assume that you have done something to cause your request to be hidden from us. We can’t help you if we don’t know that you are having a problem, so please reach out to us for help if this happens to you.
Colorado NetDMR help
- Phone: 303-691-4046
- Email: cdphe.wqnetdmrhelp@state.co.us
Who is the Administrator for the DMR Signatory role?
When someone who has requested the Signatory role for a permit is approved, the system automatically gives that person three roles. Each of those roles caries a different set of “skills” that they need to be fully functional in NetDMR. Those roles are: Signatory, Permit Administrator, and View. The skills associated with the Permit Administrator role are for controlling access to the permit. A Permit Administrator can approve, deny, and revoke the following roles for their permit: Edit, Permit Administrator, and View.
Under normal circumstances, State officials do not approve requests for roles other than Signatory. If you are having When you request the Edit, Permit Administrator, or View role you must follow up by letting your local Permit Administrator know what you have done. NetDMR will not send them an email message!
Choosing the Signatory role for a Colorado-issued permit
Whether you request the DMR Signatory role for a permit as the one who is legally responsible for that permit or you request that role as the responsible person’s representative the DMR Cognizant Official, everyone who requests the Signatory role for a permit issued by the State of Colorado must follow the same NetDMR procedure when requesting that role. They must claim and assert the authority that must already have been established for them through their permit by choosing the option on the "Additional Information Required" page in NetDMR that is associated with the phrase, "I... have the authority to enter into this agreement for the permittee under the applicable standards."
Those who select that option, will be given the opportunity to electronically sign and submit a version of the Subscriber Agreement (contract) that was specifically designed for those who are officially authorized to sign permit compliance documents such as DMRs for the permit that they are requesting the Signatory role for.
Please do not falsely claim that you have authority when you don’t actually have it by signing the Subscriber Agreement if you are not actually described in official documents on file with the Colorado Water Quality Division in association with the particular permit that you are requesting this role for as being either legally responsible for it or the permit compliance representative (DMR Cognizant Official) of the person who is legally responsible for it.
When requesting the DMR Signatory role for a permit issued by The State of Colorado, never choose the option that you will see on the "Additional Information Requested" page that asks you to provide information about the person who you are "…authorized by…" That option is only appropriate for those who are working with a permit issued by the EPA (not Colorado), and only for those who do not already have the authority to sign the DMRs of that EPA issued permit, which you are required to do for Colorado issued permits.
Requesting roles for permits in NetDMR: Signatory, Permit Administrator, Edit, & View
The instructions at the link above are divided into two categories based on whether or not the role you are requesting requires you to sign a Subscriber Agreement. The DMR Signatory role is the only role that requires you to sign one. We recommend that you sign the Agreement electronically for faster and more efficient processing.
What do you do with your CDX-NetDMR account when your circumstances change; you change employers, lose a client, or retire
Always keep in mind that your CDX-NetDMR account is an extension of you as a professional. Your account is always and forever yours. Do not let anyone else use your account. If they need access they need their own account. It is your responsibility to take care it. The info below should help you to do so, but if you have questions, ask for help.
As a professional, if your employment or contracting situation changes, you need to be concerned about two things. First, what roles do you have for permits that you should not continue to have? Second, what will you do with your CDX-NetDMR account once you have deleted all of the roles that you should not continue to have?
Always delete permit roles when your employment situation changes.
You should not keep any role for any permit once your relationship with the organization that the permit was issued to changes in a way that makes it inappropriate for you to continue to have access to their DMRs through your CDX-NetDMR account.
As a professional, you should not put yourself get into a position where you could be blamed for something that affects the permit compliance of a previous employer or client after your relationship with that organization ends. The permit holder should also not have to worry about what you might do, inadvertently or otherwise, after you are gone.
Once you have fulfilled all of your obligations (written or verbal) to do whatever you have agreed to do for the permit holder, delete all of the roles that you have for their permit(s). If they end up needing your services again later you can always request those roles again at that time. HOW TO: delete your own permit/DMR roles. HOW TO: lock your account before you abandon it
Lock and abandon your NetDMR account or take it with you?
When your employment situation changes, you have two options for dealing with your NetDMR account. You can either lock it before you abandon it (instructions above) or you can update it and take it with you to your next job (instructions below). If you decide that you do not want or need your account, be sure to delete all of the roles that you have for every permit that you have access to before you lock your account. Once you have locked your account. If you need it again in the future it can be unlocked by a Regulatory Authority Administrator.
If you decide to take your account with you, you must change the email address that is associated with it so that you will be able to reset the password when it expires. Once you get to your new job, all that you need to do to get going again is to associate your account with your new employer’s organization and make that organization your primary organization before you request access to any of their permits. Remember that if one of your responsibilities is to sign DMRs for your new employer, they must officially update their permit to add you to it as someone who has that authority before you request the DMR Signatory role for their permit. HOW TO: take your NetDMR account to your next job
Colorado NetDMR training webinar
Click the link HERE and register for one of our NetDMR training webinars. Our training is strongly recommended for anyone who will not be personally guided by someone who is familiar with the best ways to use NetDMR. There are numerous pitfalls in this system that are easy to stumble into and many ways of doing things that may work under some circumstances but that will eventually get you into trouble. You will not save any time by trying to figure this system out on your own.
Our training is designed to provide you with the most effective ways of doing what you need to do. You will also learn how to confirm that you have met your discharge data reporting requirements and more importantly know when things have gone sideways so that you can ask for help or resolve the issue yourself.
We offer two NetDMR training classes per month, on the 2nd and 3rd Fridays from 9-Noon. The class is offered through a Zoom meeting. The class is about 2/3 hands-on actually doing what you need to do, and 1/3, a description of and info about how to use the guidance and procedural documents that we provide to you with a copy of after class. The class schedule is found in the pick list at the top of the form that you must fill out and submit to register for one of our classes.
Resources:
Blank DMR form - Use this form when reporting information such as PFAS data that must be submitted for permit compliance but that isn't coded into a DMR form that has been specifically customized for your permit.
DMR Guidance - How to summarize your discharge data for entry onto your DMR report
DMR calculations workbook - Small WWTF operations log and data worksheet
DMR status codes information - The status of your DMR can be used by you to track how far along the processing path that report is as it goes from being a blank form to having the data on it uploaded to the compliance database. This document describes each of the status categories, so that you can understand what is going on with your DMR at each point of the process.
NODI codes table – NODI codes are used to explain why you are leaving one or more of the data value fields on your DMR, blank. In general you are required to report discharge data on your DMR. If you have no data to report for one or more of the pollutant parameters that you are required to report data about, you must indicate why that/those data values are absent. Some NODI codes indicate reasons for not having data that are permit violations. All permit violations require an explanation that you must put into a cover letter that you attach to your DMR before you submit it.
CDX account management procedures – Follow the instructions in this document to complete tasks such as changing the password, security questions, organization info, or email address associated with your CDX account.
NetDMR Permit Administrator procedures – Permit Administrators are responsible for approving, denying, & revoking: Edit, Permit Administrator, & View role requests of other users. You must ask the Regulatory Authority to revoke a Signatory who left your organization and did not delete their roles before they left.
How to revise/Correct a DMR that was submitted through NetDMR – If you need to correct a DMR, you must correct that DMR using the same submission method as the original report. If it was originally submitted through NetDMR, you must follow the instructions at the hyperlink above to correct it and resubmit it through NetDMR. If the report was originally submitted on a paper form, you must find and make a copy of the original paper report, strike through any incorrect information on that report, then write the corrected information above the place where you drew a line through the incorrect info. Next, use a highlighter to highlight each corrected data value. Next, use a contrasting color of ink to sign and date the corrected report on top of the original signature and date. Finally, deliver the corrected report to the Water Quality division.
Electronic Reporting Rule waivers – what you must do to qualify for a waiver and how to apply
Deleting roles locking account
However, since that e-signature will be always and forever tied to your CDX account it is important that you guard your account against misuse. Do not let anyone use your account. If you decide to abandon your account when your current employment ends, be sure to delete the roles that you have for any and all permits and lock your account before you do.
How to change the Program Service role on an existing account? - Your CDX account is very changeable. You can add a new Program Service to your account at any time. You can also deactivate one Program Service role and activate a different one if your responsibilities change. If you gain additional responsibilities and need to be able to sign and submit DMRs, you can deactivate a Program Service role that does not have an electronic signature associated with it and “Request a New Role” that does. Upsizing to a Program Service role that is more capable does not lead to system conflicts. However, downsizing to a more restricted Program Service role will cause conflicts if you do not delete all of the incompatible Permit/DMR roles that you have for any and all permits before you activate that more limited role. If you try to retain Permit/DMR roles that are incompatible with a downsized Program Service role, you will be locked out of NetDMR as soon as you activate that limited role. To fix the problem, reactivate the more capable Program Service role, enter NetDMR, and delete any incompatible Permit/DMR roles, then reactivate the limited Program Service role. How to deactivate your current NetDMR Program Service role and activate a different one.