Look out! It’s coming: EPA’s National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule (catchily referred to as the “NPDES eRule”) reaches full effect on December 21, 2025. And it’s up to water utilities’ IT teams to bring them into compliance.
The NPDES eRule requires water utilities to move all their reporting to a standardized, digital format, using online portals either provided by EPA or custom-created by individual states. That means no more submitting spreadsheets, docs, or PDFs by email, and certainly no more hard copy paper reporting by snail mail.
December of 2025 may seem a long way off, but the NPDES eRule is broad, sweeping, and impacts every form of EPA reporting a water utility is responsible for. IT teams need to get moving now if they’re going to meet new compliance requirements on time.
This article provides all the information you and the rest of your team needs to understand new electronic reporting regulations, and bring your water utility up to date ASAP.
What Is Electronic Reporting?
For the purposes of this article, “electronic reporting” (or “eReporting”) refers to using standardized online tools or web portals to submit reports to EPA. This is distinct from submitting reports by email, which many utilities did (and still do).
The NPDES eRule was published on October 22, 2015, and came into effect December 21, 2015. It’s still in the process of being implemented. It will be fully implemented on October 22, 2025.
The eRule has two phases: Phase I and Phase II.
Phase I of the NPDES eRule is already in effect. It only requires utilities to eReport DMRs.
Phase II was slated to come into effect December 2020, but the deadline was extended. On September 23, 2020, EPA signed an extension into effect. The new effective date for Phase II is December 21, 2025.
The full list of reports affected by Phase II include (per EPA’s website):
- Notices of Intent to discharge (NOIs) under a general permit
- Notices of Termination (NOTs) of coverage under a general permit
- No Exposure Certifications (NOEs) under a stormwater general permit
- Low Erosivity Waivers (LEWs) under a stormwater general permit
- Concentrated Animal Feeding Operation (CAFO) Annual Program Reports
- Municipal Separate Storm Sewer System (MS4) Program Reports
- Pretreatment Program Annual Reports
- Significant Industrial User (SIU) Bi-annual Compliance Reports in municipalities without approved pretreatment programs
- Sewer Overflow/Bypass Event Reports
- Clean Water Act (CWA) Section 316(b) Annual Reports
As you’ve probably already realized, preparing these reports is much more labor intensive than preparing DMRs. For every instance at your water utility where they exist in the form of spreadsheets or written documents, you will need to convert these documents to electronic formats compatible with new eReporting standards.
The most effective way to prepare for the full, Phase II rollout of the NPDES eRule is to transition now to a compliance and reporting system that is compatible with EPA’s new online reporting systems.
What Stage Are You at in Your Electronic Reporting Journey?
In order to get a clear idea of what steps your department must take to implement new, eRule-compliant reporting at your water utility, it’s essential to complete an audit of your current system.
Refer to the following categories to get an idea of where you stand, and plan the next steps you need to take to fully digitize your reporting and become compliant with eRule.
Stage 0: Cluttered Desk
Your reporting systems are tied up in a byzantine system of printouts, hard media (anything from floppy disks to USB sticks), and even the occasional quilt of Post-It notes. Completing a report means cracking open the filing cabinets of multiple stakeholders, and sometimes literally digging up old files.
If this sounds like your utility, you can take some comfort in the fact that you are not alone. A surprising number of water utilities across North America are still using analog—and often disorganized—systems to store and transmit data.
It comes with a lot of potential pitfalls, including:
- Hard copy data lost in transit or misplaced
- Files without backup copies being damaged or destroyed
- Significant time costs associated with manual and analog processes
- Loss of access to documents as older team members retire
If you’re at Stage 0, you’re most likely still filing reports by snail mail. You’ve got a long road ahead of you to come into compliance with the NPDES eRule. The good news is that, if you start now and get set up with a digital system that’s in full compliance with the new reporting standards coming into effect at the end of 2025, you should be able to meet the deadline.
Stage 1: Basic Electronic Reporting
You create, share, and file your reports (and associated data) on the computer. When filing reports or sharing information with colleagues and across organizations, you save data in the form of Microsoft Office or Excel files, or PDFs, and send them as attachments to emails.
All of the digital data at your water utility is stored in-office, on employee computers, or on a shared local server accessible via intranet.
Common pitfalls at this stage include:
- Lost data, as hardware is upgraded or experiences failures
- Duplicate data, in the form of multiple files stored natively on different employees’ desktops (changes to files aren’t synced, so different copies may disagree with one another)
- Vulnerability to viruses and ransomware
- Danger of sabotage or information theft. Email is one of least secure means of transmitting data online, and leaves you open to interference from a variety of bad actors, from amateur hackers to hostile foreign governments
- Information islands. An individual who relies on DIY Excel “cheat sheets” to access data or complete reports can become a weak link in an organization. When such an individual leaves on vacation or retires, even if their files are accessible, they aren’t necessarily usable by other people in the organization—leading to knowledge gaps and stalled workflows
If your water utility falls under this category, you’re one step closer than Stage 0 to meeting the requirements of the NPDES eRule. But, broadly speaking, you still have the following steps to complete:
- Assess the scope of migrating to a new compliance and reporting system compatible with the NPDES eRule
- Compile data from across disparate storage methods and file formats
- Input it into the new system
- Retrain personnel in the new system
- Adapt workflows so that all data entry and recall and report filing are completed exclusively within the new system
Completing Step 1 should help you understand the time cost of the transition. The sooner you get started, the better.
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Stage 2: Web-based
Your water utility is already using a reporting and compliance system that is fully compatible with the NPDES eRule.
This system could be:
- Fully customized. As a one-time purchase from a software company, your water utility management suite was custom-coded by their in-house engineers to meet the specific needs of your organization. Most likely, it’s locally hosted on your own servers. Changes to the software may require hiring engineers to modify the code.
- Fully configurable. The software you use was created with as many configurable variables as possible, so it can be used by a large number of utilities across a wide range of use case scenarios. It’s hosted externally, in the cloud, using standard bank-grade encryption. The software automatically updates to ensure it’s always in compliance with changes to reporting standards.
You can learn more from our article, Configurable vs. Customizable Software: A Cost-Benefit Breakdown.
In either case, your system should be up to the task of completing, filing, and storing copies of reports in accordance with the NPDES eRule. If it isn’t, you should contact the manufacturer regarding updates—or else begin looking for a new software solution.
If you have a system like this in place, you’re head and shoulders above most water utilities in terms of coming into compliance with new reporting standards and improving the overall performance and data security of your organization.
If you don’t have a system like this in place, getting to Stage 2 should be your number one priority. It’s the surest way to help ensure you’re in compliance with the new rules.
On top of that, using a web-based compliance and reporting system means:
- Data entry is easy. Predetermined forms and fields set specifically for your needs and standardized across the organization streamline the process of entering data and keeping it securely stored.
- You spend less time searching for forms and information. A searchable database with organization-appropriate tagging makes it easy to look up info when you need it. No more long email threads as you try to track down misplaced files.
- Everyone is on the same page. Whether data is hosted on a local server or in the cloud, team members are always referring and making changes to the same, authoritative file. No more out-of-sync duplicates.
To better understand the benefits of a web-based solution, check out our article, Why SaaS Makes Sense for Water Now More than Ever Before.
Stage 3: CROMERR and the Future
Even though Stage 2 should be your number one goal, there is an extra level of compliance that will soon become relevant to your water utility.
The Cross-Media Electronic Reporting Rule (CROMERR) sets standards for NPDES-compliant electronic reporting systems. In particular, it ensures that all data entered is legally defensible, and includes a Copy of Record.
To be clear: It isn’t up to your water utility to apply for CROMERR. Rather, software manufacturers for water utilities must ensure their products are compliant and apply.
CROMERR is not fully in effect yet. However, if you are choosing an electronic reporting and compliance system for your water utility, before purchasing one, you should either make sure it is already CROMERR-compliant, or that the manufacturer has a clear timeline for bringing its software in line with CROMERR standards.
The Time for Action Is Now
EPA’s new eReporting rules may seem like a major obstacle. And there is no denying that, for many water utilities, becoming compliant will take a considerable amount of planning and effort.
But these new standards are simply an indicator of the direction water utility reporting is headed. Across a wide range of industries, fully digital and cloud-based reporting and data storage are becoming the norm. Utility reporting is no different.
There are many benefits that come with bringing your water utility in line with the new requirements, including increased efficiency and less risk of data damage, loss, or theft. Even if making the transition poses some difficulties, it will pay off in the long run.
If your water utility is at Stage 0 (“Cluttered Desk”), you can save yourself a significant amount of time and energy by skipping Stage 1 and going straight to Stage 2. Plugging data into spreadsheets is a stopgap solution, at best.
Eventually, all utilities will need to become NPDES eReport compliant, and that means using a web-based solution like Klir.
Harness The Power of SaaS With Klir
We believe that utilities deserve world-class software custom-built for the water industry. Ready to see how scalable, flexible, continuously improving SaaS tools can help your utility overcome its biggest data challenges? Book a demo and get a tour of Klir today.