EPA NPDES eReporting Requirements: NetDMR, NeT, and the Submittal Stack

A new staff scientist asks where to submit a stormwater Notice of Intent for an industrial facility. The PM says “NetDMR.” You correct her: NetDMR is for DMRs. NOIs go through NeT. Then she asks about an MS4 program report and the answer becomes “NeT, but a different module.” The EPA NPDES Electronic Reporting Rule has been in force since 2015, but the submittal stack has accumulated enough modules that nobody at a small consulting firm has the whole map in their head.

This walks through what each tool covers, where state implementation diverges from federal default, and how to actually submit a report when you’re sitting in front of the regulated facility’s data on a deadline. Phase 2 of the rule reached its compliance deadline December 21, 2025; if your client is still submitting paper forms in 2026, that’s a current violation, not a future risk.

What You’ll Need Before Submitting

An EPA CDX (Central Data Exchange) account for the user submitting and the user signing. Signatory authority requires the responsible corporate officer (per 40 CFR 122.22) or their authorized representative.
The facility’s NPDES permit number. For state-issued permits this is the state-program number; for federal permits, the EPA-assigned ID.
A copy of the permit’s monitoring requirements — outfall identifiers, parameter list, sample types, frequencies, and reporting periods. Your data entry must match these exactly.
Lab EDDs or PDF reports for the monitoring period being reported.
Knowledge of which authorized program runs the permit — EPA directly, an authorized state, or an authorized tribe. State implementation determines which tool you use.

Step 1: Map the Form to the Tool

The eReporting Rule covers three categories of submittals, each routed through a different tool:

Form / Report Type	Tool	Phase
Discharge Monitoring Reports (DMRs)	NetDMR (EPA) or state eDMR	Phase 1
Notice of Intent (NOI), general permit	NeT module per permit, or state NeT	Phase 2
Notice of Termination (NOT)	NeT or state NeT	Phase 2
No Exposure Certification (NOE)	NeT (stormwater) or state	Phase 2
Low Erosivity Waiver (LEW)	NeT (stormwater) or state	Phase 2
CAFO Annual Program Report	NeT-CAFO or state	Phase 2
MS4 Program Report	NeT-MS4 or state	Phase 2
Biosolids Annual Report (40 CFR Part 503)	NeT-Biosolids (federal program states)	Phase 1

Phase 1 (DMRs and biosolids) had a December 21, 2016 compliance deadline. Phase 2 (everything else above) had a December 21, 2025 compliance deadline. Both are live. Paper submittal is no longer accepted in any authorized program except under a pre-approved waiver.

Step 2: Confirm Your State’s Implementation Status

An authorized state can either:

Adopt EPA’s tool — the regulated facility submits through NetDMR or NeT directly, and the state receives the data via the ICIS-NPDES Data Submission service.
Operate a state-built equivalent — the regulated facility submits through the state’s system, and the state forwards data to ICIS-NPDES.

The practical effect: the URL the consultant uses depends on the state. Texas (TCEQ) operates its own STEERS system for NPDES eReporting; New York operates a state portal; many smaller states use NetDMR directly. Check the EPA NPDES eReporting page for the current implementation matrix — states have moved between models as Phase 2 came online.

Common Mistake A consultant submits a DMR through NetDMR on behalf of a Texas client. Two months later the client gets a notice of violation for a missed DMR. Reason: Texas required submittal through STEERS, not NetDMR; the NetDMR submission was never received by TCEQ. The state implementation map is the first check, not the last.

Step 3: Set Up CDX and Signatory Approval

NetDMR and NeT both authenticate through EPA’s Central Data Exchange (CDX). For each new client facility, you typically need:

Register the responsible corporate officer (signatory) in CDX with their own login. The signatory cannot delegate to a consultant for a true signature — they must sign their own submissions.
Register the consultant as a preparer with permission to enter data and route to the signatory for review and submission.
Request signatory authority for the specific facility’s permit. EPA validates the request; for some programs this requires a paper Subscriber Agreement signed and mailed in (yes, mailed). Allow 2–4 weeks for first-time signatory setup — longer if the agreement gets routed wrong.

The consultant prepares; the signatory signs. Skipping the signatory step or having a consultant sign on the officer’s behalf is a falsification finding when audited.

Step 4: Enter the Data and Submit

For DMRs through NetDMR, the workflow is: select the facility, select the monitoring period, select the outfall, enter results parameter-by-parameter against the permit’s required limits and units. Non-detects use the “less than” symbol with the reporting limit value. The system flags exceedances against permit limits inline; an exceedance must be accompanied by a violation explanation.

For NeT submittals (NOIs, NOTs, MS4 reports, etc.), the workflow is form-based: complete each field per the program module’s template. Many NeT forms allow saving a draft, but the signatory still has to sign within the system before submission is complete.

For an actual DMR walkthrough including unit conversions and the “hard-stop on exceedance without comment” behavior, see submitting NPDES DMRs through NetDMR.

Step 5: Verify ICIS Receipt

Submission is not the final step. The data routes from NetDMR or NeT through the ICIS-NPDES Data Submission service to EPA’s Integrated Compliance Information System. Verify in EPA’s ECHO that the submission appears in the facility’s record within 1–2 weeks. If it doesn’t, something failed in the data sharing step — the state may not have transmitted, or ICIS may have rejected the record on schema validation.

Pull the ECHO record at the start of every quarterly cycle. It’s the only way to confirm that what your client submitted is what the federal compliance system has on record.

Common Electronic DMR Submission Gotchas

Reporting period vs. submission deadline. A DMR for the March monitoring period is typically due by the 28th of the following month under federal default; some states require the 15th. Submitting late is a violation regardless of when monitoring occurred.
No-discharge months. Even if the facility didn’t discharge, a DMR still has to be submitted with “NODI” (No Data Indicator) codes. Skipping the report is a violation; submitting NODI is compliance.
Rounding and significant figures. Permit limits often include decimal places that must match exactly. Reporting 0.05 mg/L when the permit limit is 0.050 mg/L can trigger a system flag depending on configuration.
Exceedance reporting trigger. A DMR exceedance does not always trigger immediate notification. NPDES permits typically require 24-hour notice for upset conditions and 5-day written follow-up; routine exceedances are reported on the DMR itself. See NPDES exceedance reporting timelines for the full notification matrix.
Stormwater MSGP differences. Industrial stormwater facilities under the MSGP submit benchmark monitoring through NeT-MSGP, not the standard NetDMR — benchmarks are not effluent limits. The forms and the consequence-of-exceedance both differ. The stormwater permit compliance checklist covers this in more detail.

The EPA’s NPDES eReporting page publishes the current authorized-program implementation status and the per-form module list. It’s the source of truth for which tool a particular state requires for a particular form — check it at the start of any new client engagement before assuming federal default.