CROMERR WORKING GROUP
2012 Exchange Network National Meeting
Pam Osnaya: State of Montana
Peter Stubbs: CGI
Agenda
2

What is CROMERR?

Background

Cross-State CROMERR Working Committee

* CROMERR Roadmap for MT Department of Environmental Quality (DEQ)

Open Discussion

Next Steps
* The Montana CROMERR Roadmap has not been finalized and all information presented should be
considered a DRAFT.
What is CROMERR?
3
Cross-Media Electronic Reporting Regulation
(CROMERR)

Provides the legal framework for electronic reporting
(eReporting) under all of EPA’s environmental regulations


Establishes standards for receiving documents electronically that are
submitted to satisfy requirements of a 40 CFR program.
These standards cover a variety of system functions, such as electronic
signature validation.
Background
CROMERR Working Committee
4
Formed in April 2011

At the 2011 National Exchange Network Meeting, Montana and Oklahoma
formed the CROMERR Working Committee

Partnered with CGI to facilitate

Tom Copeland (Oklahoma) served as Mentor (Thank You Tom! )

Committee met Aug 25 – Oct 20, 2011

15+ states and agencies participated
Background
CROMERR Working Committee
5
• Develop a Generic Roadmap
• Include components and architectural strategy
• Achieves compliance for small states and agencies
• Develop a Conceptual Approach for CROMERR-in-theClouds
• Multi-State hosted solution
• Speed CROMERR implementation
Background
Montana’s CROMERR Roadmap
6
• Exchange Network Grant
awarded to establish a
Montana CROMERR
Roadmap
• RFP posted seeking
CROMERR-experienced
consultant
• CGI awarded the contract in
December 2011
• Project launched in January
2012
Background
Montana’s CROMERR Roadmap Deliverables
7
e-Reporting Baseline Report
Business Process Flows
• Baseline of all reports submitted to MT DEQ (regardless of
format or CROMERR applicability)
• High-level view of current and future states
eReporting Policy & IT
Infrastructure Report
• Review of state infrastructure supporting eReporting and
policies, standards, constraints
Key Components List
• Components required to support eReporting and CROMERR
Architectural Designs
• Options for a CROMERR-compliant eReporting solution
Partner CROMERR Solutions
Final Roadmap
• Review of solutions developed by EPA Partner States
• A plan on how to move forward based on the findings from
the above deliverables, including associated Benefits,
Risks, and Issues
8
Cross-State CROMERR Working Committee
CROMERR Working Committee
Participating States Agencies
9
The CROMERR Working Committee consisted of a group of 15+ States and Agencies
who collaborated on a generic approach to CROMERR compliance.

Cherokee Nation

North Carolina

EPA

Oklahoma

Hawaii

Oregon

Idaho

Muscogee Nation

Indiana

National Congress of American Indians

Massachusetts

Pueblo of San Ildefonso

Mississippi

Quinault.org

Missouri

Salt River Pima-Maricopa Indian Community

Montana

Vermont

New Mexico

West Virginia

Wisconsin
CROMERR Working Committee
Goals Accomplished
10
• Included Key Components and Strategies
• Potentially a Multi-State hosted solution that can speed
CROMERR implementation at the local state or agency level
CROMERR Roadmap
High-level Business Process Flow
11
The Working Committee established a high-level
Business Process Flow showing how State Agency
personnel and regulated entities could interact through
an eGovernment portal and CROMERR solution.
MT DEQ will distribute the generic Business Process
Flow to those interested.
CROMERR Roadmap
Phased Approach
12
The Business Process Flow identifies high-level steps & IT components for CROMERR compliance.
The following summarizes recommended Key Steps:
PHASE
KEY STEPS
I
• Detailed Inventory List of Reports:
 Categorized by CROMERR vs. non-CROMERR Reports
• Strategy for processing eReports (i.e., CROMERR and non-CROMERR) through the
eGovernment portal based on the Inventory List of Reports
• Procure, develop, or leverage an eGovernment Portal for electronic submittals
II
• For CROMERR Compliance:
 Define and document Business Processes
 Procure, develop, or leverage the software components
III
• Integrate CROMERR solution with eGovernment Portal
• Train internal and external users
• Go Live – begin receiving CROMERR-compliant Reports via the Portal
CROMERR Solution
Business Benefits
13
Implementing a shared solution that can be leveraged by multiple
agencies can result in the following benefits.
BENEFIT
DESCRIPTION
1. Cost Effective
• Shared initial costs (e.g. licensing, hardware, software)
• Maintenance and upgrade costs are shared
2. Faster Start-Up
• Reduced development time
• Less time configuring agency environment
3. Ease of Maintenance
• Low level of maintenance required in agency environment
4. Optimized Staff
• Reduces ongoing effort required to host & maintain new IT components
• Staff focused on higher priorities
CROMERR Architectural Design
Conceptual Approach
14
CROMERR Working Committee
Next Steps
15
Explore how tools,
processes, and
methodologies
could be shared
across states
Continue the dialog
on CROMERR-inthe-Clouds solution
opportunities
Identify potential
state components
and/or solutions
that could be
leveraged
Reconvene the Cross-State CROMERR Working Committee upon
successful completion of the CROMERR Roadmap
16
Montana CROMERR Roadmap
MT CROMERR Roadmap
Business Motivation Goals
17
Minimize
legal
exposure
Meet EPA’s
CROMERR
Regulation
Move from paper
to electronic data
submission to
optimize resources
The Roadmap was not intended to recommend a final CROMERR solution;
rather define the required components and architectural options for moving forward
MT CROMERR Roadmap
Business Motivation Objectives
18
Define the Key Components and high-level
Architectural Options for a CROMERR-compliant
solution
Include associated Benefits, Risks, and Issues
Identify opportunities for leveraging proven
solutions
Expand the scope to include an Architectural
Vision for all eReporting
MT CROMERR Roadmap
Business Motivation Benefits
19
Components
required for the
electronic exchange
of data includes
components
required for
CROMERR
Resources
optimized through a
well-engineered,
business-led vision
for all electronic
reporting
Montana CROMERR Roadmap
Project Activities
20
Establishment of the MTDEQ Roadmap has been a 5-month effort that involved 3 primary phases.
Montana CROMERR Roadmap
Roadmap Overview
21
The Montana CROMERR and
eReporting Roadmap describes the
phases and detailed activities necessary
to move from the current state to the
desired future state.
Future
State
Phase 4
Phase 3
Go-Live with
Initial Reports
Phase 2
Procure, Design
and Develop
Phase 1
Current
State
Strategy and
Requirements
Prioritize & Implement
Additional Reports
Montana CROMERR Roadmap
Current State of eReporting and CROMERR
22
MT DEQ is taking a systematic approach to improving eReporting capabilities and attaining
CROMERR compliance.
1
1
37
55
8
• CROMERR Applications Approved
• CROMERR Applications Pending Approval
• Reports which, if received electronically, would fall under CROMERR
• Non-CROMERR Reports Received
• Reports Under Review
Montana CROMERR Roadmap
Current State of eReporting and CROMERR
23
Business
functions
worked
separately
No
enterprise
document
mgmt
strategy
Many
programs
still receive
paper
reports
Current
Challenges
No
enterprise
e-Gov
Portal
No
enterprise
back office
No
enterprise
database
Montana CROMERR Roadmap
Future Vision
24
Deliver a CROMERR-compliant eReporting environment that is scalable and flexible
enough to meet the evolving needs of the Agency and regulated community.
Promote and ensure CROMERR
Compliance
Ensure new eReports (CROMERR
and non-CROMERR) can be added
and maintained with minimal
effort and cost
The eReporting
solution should:
Have sufficient flexibility to meet
the unique needs of individual
programs without jeopardizing
agency-level efficiencies
Leverage the existing
infrastructure, tools, and
investment
Montana CROMERR Roadmap
Future State Business Benefits
25
The Future State of DEQ eReporting will provide an array of
business improvements that can be leveraged across all DEQ programs.
CROMERR Compliance
Enhanced eGovernment Services
Enhanced Data Sharing Capabilities
Improved Compliance Lifecycle
Automated Administrative Completeness Review
Enhanced Document Management Strategy
Automated Workflow
eReporting Roadmap
Recommended Phased Plan
26
The following is a recommended four-phased plan to bridge the gap
between the current and future state of DEQ eReporting
PHASE
TITLE
HIGH-LEVEL SUMMARY
1
Strategy and
Requirements
Develop a high-level Strategy for an eGovernment Portal
together with a CROMERR solution & Back Office application
Define high-level requirements at the agency and program level.
2
Procure, Design
and Develop
Procure, design or develop the eGovernment Portal and related
CROMERR solution based on the Strategy identified in Phase 1
3
Go-Live with
Initial Reports
4
Go-Live with the first group of reports required for CROMERR
compliance
Prioritize and
Prioritize and move forward with implementation of additional
Implement
CROMERR and non-CROMERR reports
Additional Reports
Montana CROMERR Roadmap
Review Proven State Solutions
27

Goal: Identify proven solutions that might serve as a model for
Montana based on Montana’s:





Business Needs
Policies and Standards
Existing infrastructure
Funding and development strategy
Decision: Final requirements and design of the Montana
Solution will be completed during the next phase of the
project.
Montana CROMERR Roadmap
State Solutions Reviewed
28

Montana would like to thank the following States for taking
time to share their CROMERR Journey with Montana:









Delaware (*) – Dennis Murphy
Indiana – Will Richey
Mississippi – Melanie Morris
New Jersey (*) – Jim Bridgewater & Ralph Smith
North Dakota – Gary Haberstroh
Ohio – Adele Vogelgesang
Oklahoma (*) – Tom Copeland
Texas – Jackie Ogle
Washington (*) – Miles Neale
(*) Those solutions that align the best with Montana’s business needs, existing infrastructure,
and current IT Policies and Standards
Montana CROMERR Roadmap
Leverage Lessons Learned
29
Secure high-level
buy-in &
participation
#1 Reported
Lesson Learned:
Ensure the
Program
effort is
participation is
key: ensures
Business-Led Analyze internal
depth & breadth
of knowledge
across the
business &
solution
and external user
needs
Montana CROMERR Roadmap
Leverage Lessons Learned
30
Don’t forget
Administrative
and Usability
efficiencies in
the design
Acquire an
EPA-approved
solution from
another
state/agency
over building
locally
When Picking
a Solution:
Don’t develop
custom
processes for
each program
Design/pick a
solution that is
Simple and
Reusable
Standardize
Business
Processes
across the
enterprise
Montana CROMERR Roadmap
Leverage Lessons Learned
31
Start with a small
program
Seek mentors
from other
agencies that
have been
there
Develop EPA
contacts early
to gain
frequent
feedback
Montana CROMERR Roadmap
Next Steps
32

Finalize the DRAFT of the CROMERR Roadmap


Present the CROMERR Roadmap to the MT Governance
Board



July 2012
August 2012
Governance Board Action Items:
 Evaluate proposed opportunities
 Determine next steps
Reconvene the Cross-state CROMERR Working Committee
33
Open Discussion
 Challenges becoming fully CROMERR Compliant: what small
states and Agencies are facing
 Additional Lessons Learned: by States that have implemented
CROMERR
 Enterprise vs. Program level approach
 Participant Interest: Identify additional States and Agencies
that would like to participate in an on-going dialog about the
possibility of a CROMERR In-The-Clouds offering
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Questions?