1. NPDES Electronic Reporting Rule
Deliberative Product --- Not for Release
NPDES Electronic Reporting Rule
EPA’s Construction General Permit
(CGP) for Stormwater Discharges

2. Objective
Provide an overview of the transition from eNOI to CGP NeT
Introduce key terms and system processes for electronically filing
Explain and demonstrate some key features and functionality of the CGP NeT tool
Provide you with support and resource information to assist in your transition from eNOI to CGP NeT

3. Overview of CGP
New 2017 CGP recently signed and will be effective Feb 16, 2017
Who needs to apply for coverage?
Operators in an area where EPA is the NPDES permitting authority (see Appendix B of the CGP)
Operators of construction activities that will disturb one or more acres of land, or that will disturb less than one acre but are part of a common plan of development or sale that will ultimately disturb one acre or more.
Operators requiring permit coverage include any party associated with a construction activity that meets either of the following two criteria:
The party has operational control over construction plans and specifications, including the ability to make modifications to those plans and specifications; or
The party has day-to-day operational control of those activities at a project that are necessary to ensure compliance with the permit conditions (e.g., they are authorized to direct workers at a site to carry out activities required by the permit).
Where there are multiple operators associated with the same project, all operators are required to obtain permit coverage.

4. Overview of CGP
Existing projects covered under the 2012 CGP that extend beyond February 16, 2017, will have until May 17, 2017, to submit a new NOI to continue permit coverage
For existing projects that will not continue, users may:
Elect to submit a Notice of Termination (NOT) in eNOI; OR
Just allow their 2012 coverage to expire
Emergency-related project (i.e., a project initiated in response to a public emergency (e.g., mud slides, earthquake, extreme flooding conditions, disruption in essential public services), for which the related work requires immediate authorization to avoid imminent endangerment to human health or the environment, or to reestablish essential public services), you will be required to submit a new NOI using CGP NeT no later than 30 calendar days after commencing construction activities to be covered under the 2017 CGP.

5. Waivers (Appendix C of CGP)
Waivers in lieu of needing to obtain coverage under this general permit are only available to stormwater discharges associated with small construction activities (i.e., 1-5 acres)
Qualification for Waivers are based on:
a low rainfall erosivity factor (R-Factor)
a TMDL analysis
an Equivalent Analysis that determines allocations for small construction sites are not needed
Operators must notify EPA of its intention for a Waiver
Where the Operator changes or another is added during the construction project, the new Operator must also submit a waiver certification to be waived.

6. Waivers (Continued) Waiver Deadlines
Waiver certifications must be submitted prior to commencement of construction activities.
If you submit a TMDL or Equivalent Analysis waiver request, you are not waived until EPA approves your request. As such, you may not commence construction activities until receipt of approval from EPA.
Late Notifications: Operators are not prohibited from submitting waiver certifications after initiating clearing, grading, excavation activities, or other construction activities. The Agency reserves the right to take enforcement for any unpermitted discharges that occur between the time construction commenced and waiver authorization is granted.

7. Used to obtain coverage under the 2017 CGP
Notice of Intent (NOI)
Used to obtain coverage under the 2017 CGP
Undergo 14 day review process when Certified
Can be placed “on hold” by EPA
Review clock resumes when record is “released” if fewer than 14 days have passed since submitting the NOI
If “on hold” status extends beyond the 14 day review period, NOI record is ‘Active’ when record is “released”
Can be terminated/rejected by EPA
Can be changed via Change NOI
Coverage can be terminated via Notice of Termination (NOT)

8. Low Erosivity Waiver (LEW)
Qualifications:
Acreage to be disturbed less than 5 acres
R-Factor less than 5
R-Factor can be calculated using EPA’s online calculator at
If Project Start/End Dates change, R-Factor must be recalculated
If Operator changes, new Operator must also apply for LEW
Must be submitted prior to commencement of operations
Can be changed via Change LEW
Can be Discontinued

9. Notice of Termination (NOT)
Used to terminate CGP coverage
Conditions for termination have been met (see Part 8 of the permit) and coverage under the CGP is no longer needed:
Construction activities have ceased and final stabilization has been met; or
Operator has transferred control of the site to another operator who has submitted an NOI; or
Operator has obtained NPDES permit coverage under a different permit

10. Relevant Terms and Acronyms (see Appendix A of Permit for more)
Term Acronym Definition
Central Data Exchange
CDX
Point of entry on the Environmental Information Exchange Network for environmental data exchanges to the Agency. A CDX account is required to access CGP forms.
NPDES eReporting Tool
NeT
Data application used to enter/submit NOIs, LEWs, and NOTs.
Notice of Intent
NOI
Used to obtain coverage under a General Permit.
Low Erosivity Waiver
LEW
Used by small Operators who qualify for a waiver based on their rainfall erosivity factor and project size
Notice of Termination
NOT
Upon completion of construction, the Notice of Termination allows Operators to terminate their CGP coverage.
Certifier
None
The entity authorized to certify forms, see, Signatory Requirements, for certifier criteria.
Preparer
The individual preparing forms. This may be the certifier or an individual the certifier designates to prepare the form.

11. Overview of CGP Electronic Reporting
Previously used the eNOI system
Starting February 16, 2017, new NOIs and LEWs will be submitted in the NPDES eReporting Tool (NeT)
Why NeT? NeT is linked to other EPA data systems so CGP data can be shared across the Agency and with the public
No CGP records are being migrated from eNOI to NeT
CGP records previously submitted under previous CGPs can be found on the eNOI Search Tool
Users with CDX accounts will simply have to add CGP NeT program service to their account

12. Gaining Access to CGP NeT - Login and Add Program Service
Log into CGP NeT (
Existing CDX User (eNOI, NeT, NetDMR)
Enter User ID and Password
Manually Add Program Service for NeT EPA CGP
Certifiers may be asked to sign Electronic Signature Agreement if haven’t done so already
New CDX User
Register from within CGP NeT

13. Determine your Role
Certifier
Prepare, Certify, and Submit NOIs/LEWs/NOTs to EPA
Must be authenticated in CDX
Cannot be delegated
Preparer
Prepare an NOI/LEW/NOT for the Certifier

14. Already Have CDX Account Add NeT EPA CGP Program Service
Existing User
Already Have CDX Account
Add NeT EPA CGP Program Service

15. Add CGP Program Service
Visit CGP NeT (
Login with your CDX User ID & Password
You will be taken to your MyCDX Home Page
If you’ve forgotten your User ID or Password, click on the corresponding link and follow the instructions
Click Add Program Service
Select the “NeT: NPDES eReporting Tool” Program Category
Select the “NeT - EPA Stormwater Construction General Permit” Program Service
Select Role
Preparers are finished. Certifiers continue with authentication process (next slide)

16. User Authentication – Certifiers Only
If you have never signed an Electronic Subscriber Agreement (ESA) with CDX before, you will be asked to do so
Confirm that the name you have provided is accurate and that you want to proceed with LexisNexis authentication
If you do not wish to proceed with electronic authentication, there is a paper option. Please note, that using the paper option will take several days to complete
Enter your personal information into LexisNexis for authentication
Please note that the data entered into LexisNexis is not saved, stored, or retained. It is used for authentication purposes only
If rejected by LexisNexis, you must use paper ESA option
Select and answer 5 security questions
These security questions will be used when Certifying CGP forms. When certifying a form, one security question will be randomly chosen for you to answer
Answers to the security questions are case sensitive
If you have previously signed an ESA in CDX, you need only Select and answer the 5 security questions.

17. Requires CDX Registration
New User
Requires CDX Registration

18. Go to CDX and Register
Visit CGP NeT (
Click on the Create New Account link
Select Role
Users can only have 1 Role assigned
Enter your Personal Information
Create User ID, Password, Answer 3 security questions
For Certifiers, select and answer 5 additional security questions
Enter Organization Information
If your Organization does not exist in the system, you can request to have it added
Enter Phone &
You will receive an with a verification code. Copy & Paste the verification code into the Verification field
Preparers are now finished. Certifiers will need to authenticate

19. User Authentication – Certifiers Only
Certifiers will need to complete additional steps to authenticate
Answer the LexisNexis Questions
Use personal information
Data is not stored or saved
Electronically sign the Subscriber Agreement
Can choose to submit paper ESA
If LexisNexis fails, must submit paper ESA
Paper ESA will take several days to process

20. Intro to CGP NeT

21. System Features Internet Accessible 20 minute time out
Can use computers, laptops, tablets, or smartphones
Can use Internet Explorer, Firefox, or Chrome
20 minute time out
20 minutes of inactivity will log the user out
Related Questions
For some questions, depending on the answer provided, additional questions will appear
Business Rules
CGP NeT forces some data fields to meet specific formatting requirements
User is notified immediately if business rule is not met

22. Preparer/Certifier: Certifier Only: What Can I do in CGP NeT
Create new, Change, Terminate NOI
Create new, Change, Discontinue LEW
Route form to other Preparer/Certifier
Recipient must also be a CGP NeT user
Certifier Only:
Certify NOI (including Change & Terminate)
Certify LEW (including Change & Discontinue)

23. CGP Form Status Status Definition Draft
An NOI or LEW that has been created but not yet Certified. Draft forms can be Edited or Deleted.
Submitted
An NOI that is currently within the 14-day review period. Submitted forms can not be edited. If changes need to be made, the form is to be deleted and a new NOI created.
On Hold
An NOI that EPA has placed in a temporary suspension for further analysis/review. On Hold forms can not be edited or deleted.
Active
An NOI that has completed its 14-day review or a LEW that has been certified. Active forms can only be Changed/Terminated.
Terminated
An NOI that has been terminated. Terminated forms can not be unterminated or modified.
Discontinued
A LEW that has been discontinued. Discontinued forms can not be restored or modified.
Denied
A CGP form that has been rejected by EPA. Consult with your EPA office as to the specific reasons for rejection. Denied forms can not be edited or deleted.
Archived
When an NOI or LEW has been changed (and becomes Active), the original form is archived and is no longer Active. Archived forms can not be edited or deleted.

24. Launching CGP NeT (after CGP Program Service has been added)
Visit CGP NeT (
Login with your CDX User ID & Password
You’ll be taken to the MyCDX Home Page
Click on the Role next to the CGP Program Service
CGP NeT is launched

25. Entry way to EPA tools & systems CGP ‘widget’ allows for:
E-Enterprise Portal
Entry way to EPA tools & systems
CGP ‘widget’ allows for:
Search existing NOI/LEW public records (i.e., submitted, active, and terminated forms)
See Detailed Information from these forms
Check Status of Review for submitted forms
Download corresponding attachments
URL –

26. [DEMO OF CGP & E-Enterprise]

27. Resources CDX Assistance
Call (toll-free) or (970) for International callers (8:00am – 6:00pm EST)
NPDES eReporting Website:
CGP Assistance
Call Center at (toll-free) (9:00am – 5:00pm EST) to
EPA CGP Informational Website –
EPA CGP Support Website –

28. The URL is: https://epanet.zendesk.com
NeT Zendesk
The NeT Customer Support web page contains (or will contain soon) a wealth of CGP (and NeT) related material
User Guide
Quick Start Guide
GovDelivery ( subscription service)
Training Schedule
The URL is:

29. Questions?