The file should answer
- Which property is this?
- Why was it in the access workflow?
- Who was contacted?
- What role did each person have?
- Which attempts were made?
- Which methods were used?
- What document or waiver was presented?
- Was access granted, refused, incomplete, or non-responsive?
- Was it ever crew-ready?
- Where did each record come from?
- Can the event sequence be verified?
- What would be produced to the state, engineer, counsel, or reviewer?
What ES-R requires
- Access activity captured as discrete events, as it happens.
- Attempt and method counts derived from events — never asserted or stored.
- Every event labeled with its record source and both timestamps.
- Executed instruments and photo evidence fingerprinted at the moment of execution.
- Each property's record append-only and independently verifiable.
Regulatory crosswalk
The crosswalk maps each mandate to the record ES-R requires, in plain language. Regulatory citations describe the requirements the record is designed to document; conformance with a regulation remains the obligation of the water system.
| Regulatory mandate | Citation | What the record shows |
|---|---|---|
| Reasonable-effort outreach minimums — at least 4 attempts using at least 2 methods (federal floor; states may require additional attempts or specific methods) | 40 CFR §141.84(d)(3)(i) | Each attempt is one row in the property’s event record, with its method and its time. Attempt and distinct-method counts are computed from those rows at the moment they are needed — never stored as a bare number that could drift from the events behind it. |
| Documented refusal of access, reportable to the state | 40 CFR §141.84(d)(3); state reporting | A refusal is recorded with the same ceremony and integrity protection as a signed consent: who refused, in what role, when, and the stated reason. The property then reports as refused rather than simply going quiet. |
| Change of ownership: offer to replace within 6 months of learning of the change; new reasonable effort within 1 year | 40 CFR §141.84(d)(3)(ii) | An ownership change is itself a recorded event that restarts the outreach clocks. The renewed offer and the fresh attempt count are tracked from that event forward, with the deadlines derived from it. |
| Documentation to the state for each service line not replaced due to no access or no response | 40 CFR §141.90(e)(10) | The demonstration is the property’s complete, chronological event history — attempts, methods, dates, outcomes — exported together with an independently recomputed verification result. |
| Illinois waiver documentation: waiver presented, signed, refused-to-sign, or property non-responsive | 415 ILCS 5/17.12(ff)(1)(D) | All four waiver outcomes are recorded as events: presented (by portal, in person, or as a mail enclosure), signed, refused to sign, or non-responsive backed by the conforming attempt history. |
| Electronic notification of waiver outcomes to IDPH | 415 ILCS 5/17.12(ff) | The notification itself is recorded as an event carrying the agency, the submission reference, and the records it covered; the acknowledgment is recorded the same way. The electronic transport to IDPH is a program-specific integration. |
| Identification of the party granting access and their authority (owner vs. occupant) | 40 CFR §141.84(d); instrument validity | Every signer is recorded with their claimed role and the recorded basis for it. A grant requires an ownership-authority role; an occupant is routed to an acknowledgment instead, and the record shows the routing. |
| Record retention and integrity — records available for review, protected against alteration | 40 CFR §141.91; evidentiary practice | The record is append-only. Every event is fingerprinted together with the event before it, so a retroactive edit is detectable by recomputation; executed documents and photographs carry their own fingerprints. |
The reasonable-effort figures above state the federal floor — no fewer than four
attempts using at least two methods. States may require additional attempts or
specific methods; ES-R treats state requirements as an overlay evaluated against
the same event record.
Technical appendix — available on request
Field definitions, the event taxonomy, integrity and verification mechanics, conformance language, the procurement citation, and the version history live in the ES-R v1.1 Technical Appendix (PDF), provided to counsel, procurement, and IT on request: compliance@entrystandard.org or contact us.
Current version: ES-R v1.1, published 2026.